ML20136H431
| ML20136H431 | |
| Person / Time | |
|---|---|
| Site: | Three Mile Island  |
| Issue date: | 12/14/1984 |
| From: | Johari Moore GENERAL PUBLIC UTILITIES CORP. |
| To: | |
| References | |
| SP-I-032-K, SP-I-32-K, NUDOCS 8508200311 | |
| Download: ML20136H431 (218) | |
Text
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- 31. k-1 UNITED STATES OF AMERICA NUCLEAR REGULATORY COMMISSION 2
BEFORE THE ATOMIC SAFETY AND LICENSING BOARD 3
IN THE MATTER OF : DOCKET NO. 50-289-SP 4 METROPOLITAN EDISON COMPANY : (RESTART MANAGEMENT REMAND)
(THREE MILE ISLAND NUCLEAR :
5 STATION, UNIT NO. 1) :
6 7 DEPOSITION OF: J AMES P. MOORE , JR .
8 TAKEN BY: GOVERNMENT ACCOUNTABILITY PROJECT 9 BEFORE: ELLEN SWAYZE REISSER. REPORTER l
NOTARY PUBLIC 10 l DATE: SEPTEMBER 26, 1984, 9:30 A.M.
11 PLACE: HARRISBURG FRIENDS MEETING PLACE
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12 6TH AND HERR STREETS
, HARRISBURG, PENNSYLVANIA 33 14 15 g N APPEARANCES: 1- g
' 16 LYNNE BERNABEI, ESQUIRE '
j t2 3 18 FOR - GOVERNMENT ACCOUNTABILITY PROJE (THREE MILE ISLAND) EN r
(197 h g Cu 5%pocYBb,a SHAW, PITTMAN, POTTS & TROWBRIDGE c /
ig cw4 BY: ERNEST L. BLAKE, ESQUIRE ff g DAVID R. A. LEWIS , ESQUIRE
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FOR - LICENSEE, GPU NUCLEA sustaaa esecutest !
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22 LOIS R. FINKELSTEIN, ESQ ,g f,#1/
MARY E. WAGNER, ESQUIRE
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2 1 JAMES P. MOORE, JR., called as a witness, being sworn, 2 testified as follows:
3 DIRECT EXAMINATION 4 BY MS. BERNABEI:
5 Q Mr. Moore, for the record, am I correct that there 6 are no stipulations between your counsel and ourselves and 7 that you wish to review and sign your deposition -- review 8 your deposition and sign it?
0 A Yes, I wish to do that. I am not aware of any 10 stipulations.
11 Q For the record, would you state your name and i
U current address?
13 A James P. Moore, M-o-o-r-e, Jr., 22 Sherbrook Drive,
- 14 Florham Park, New Jersey.
l 15 Q What is your current position?
16 A Consulting engineer.
17 Q To? -
2 A To the director of engineering and design.
W Q And that's for?
20 A GPU Nuclear.
21 Q Directing your attention to March 28 of 1979, what 22 position did you hold at that time?
23 A Mechanical components manager. 1 l
24 Q Okay, and that was with the GPU Service Company, is 1 25 that correct? I 1
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l 1 A That's correct. I l 2 O Now, to whom did you report in that position -- who 1
i 3 was your supervisor?
i 4 A Don Croneberger.
5 0 And what was his position?
6 A Gee, I can't recall. I guess it was -- he was i
l 7 department head ihr engineering and design. He's currently l 8 called director of engineering and design.
l f i
9 Q Okay, but he was generally the head of the department 10 of engineering and design?
11 A That's correct.
n Q And that was again for GPU Service Company?
13 A Correct.
14 Q To whom did he report?
15 A Richard Wilson, i
16 Q And what was Mr. Wilson's position?
l 17 A I'm trying to think what we called the organization.
m It vecessentially the same position he has right now which is 19 head of technical functions.
l l 20 Q Head of technical support?
21 A Well, it wasn't technical support, that was a term l
22 that came out of the accident. I t's currently called the 23 technical functions division and it was whatever was equivalent u to that in those days, I can't recall exactly what his title 25 was.
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A 1 Q And to whom did Mr. Wilson report?
2 A Bob Arnold.
3 Q What was Mr. Arnold's position at that time?
4 A Let's see, he was -- I can't even recall -- he was 5 in charge of all the different departments around there for the 6 nuclear support, I can't recall what his title was, but he was 7 essentially the vice-president for --
8 Q Nuclear division?
9 A -- the nuclear division.
l 10 Q And it would again be for GPU Service Company?
11 A That's correct.
U O Now, on March 28th the position as mechanical 13 components manager, is that correct?
l 14 A That's correct.
15 Q W1.at were your duties and responsibilities generally?
16 A Without regard to the accident you mean?
17 Q Without regard.
M A It was mainly involved with the design and 19 construction of new nuclear power plants. This involved all l
20 the mechanical components that went into the plant, primarily l 21 pumps, heat exchangers, piping, that sort of thing.
l 22 Q Now, how many individuals did you supervise in that 23 position?
24 A At that time it was probably somewhere between 20 25 and 30.
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5 1 Q Was Mr. Wallace one of the individuals you super-2 vised at that time, were you his superior in some sense?
, 3 A I was at one point, I can't recall if at the time of i 4 the accident -- I can't recall if it was r_t that point in time 5 or.not.
r 2
6 Q Okay, it was represented in at least one of his 7 depositions he had stated at that time you were his supervisor.
8 A Okay, fine.
9 Q At least somewhere in that period you remember being 10 his supervisor?
11 A Right, some period of time prior to the accident at n least.
l 13 Q Okay, and during the period of time you were his 1
14 supervisor, what was his position and generally his duties 15 and responsibilities?
16 A Well, at the time as I recall prior to being l 17 mechanical components manager, I was mechanical systems .
- M -manager and that's the time frame which I recall that he worked 19 for me and he was primarily involved with the systems in the 20 nuclear portion of the plant, the reactor systems.
21 Q And did he have a direct reporting relationship to yot ?
22 A' At that point in time he did, yes. The point when 23 he was working for me, I can't' recall. Like I say, I don't l
M recall that he reported to me directly before the accident.
25 Q Can you describe in a short form what your educational
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t I background is?
2 A Bachelor's degree in marine engineering, and then I l 3 completed all the course requirements but I never did the 4~ thesis fcr a master's in nuclear engineering.
5 O Do you know prior to assuming your position as the 6 mechanical components manager, what was your work experience 7 either within GPU or before coming to GPU?
8 A I was with Allis Chalmers Nuclear Division. I worked 9 there for -- after about two years of working various training 10 programs for various departments, I worked in the nuclear l 11 division in fluid systems.
E Q What were the years on that?
13 A 1956 to 1968 and a couple years out in the Navy.
14 0 You said '56 to '687 l
l 15 A Yes.
16 Q Okay.
17 A From 1968 on, GPU.
18 Q And is it fair to say you've been doing primarily B nuclear engineering and design work?
20 A Well, it depends on the definition of nuclear l
i l
21 engineering. I've been working on nuclear power plants.
l 22 O Working on nuclear power plants. Now, referring you 23 to March 28th, when did you report to work that day?
N A I presume about 8:00. !
f 25 Q Where did you go at that time?
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7 1 A I don't recall when I came to work that morning but 2 at my office I presume.
3 Q And your office at that time was located in 4 Parsippany, is that correct?
5 A That's correct.
6 Q Do you recall when you learned that a site of 7 emergency had been declared at TMI?
8 A I don't recall the incident, no.
9 Q: Do you remember when you learned that there had been 10 an accident or. transient at TMI - 2?
11 A The first thing I can remember is being in two U meetings that morning and somewhere around -- I can't recall 13 the exact time right now -- but somewhere around 9:00, some-1-1 where in that time frame.
15 Q Okay, and where was this meeting, the 9 a.m. meeting?
16 A It was in a conference room in our office building.
17 0 Who else attended the meeting?
E A I'can't recall.
19 Q Just generally, was Mr. Arnold there?
20 A I don't know.
21 Q' Can you remember anyone else in'the meeting, Mr.
22 Keaton?
23 A I can -- those were people that were probably there 34 .but I wouldn't even want to guess. The-second meeting I 25 believe my notes reflect who was there but the first meeting I ,
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8 1 can't recall.
2 O Okay. Well, is it fair to say that you would have l 3 remembered.if Mr. Arnold was there, would you not, he being 4 the highest ranking official in your office?
5 A I may not have.
l 6- O Do you know if Mr. Keaton was there?
t 7 A I don't know.
i 8 Q How about Mr. Broughton?
9 A Really I don't remember who was at the first one.
10 0 I'm just trying to jog your memory a little bit.
l i
11 A Yeah, okay, but I've been trying to think when I E! looked at the notes there.
13 Q How about Mr. Broughton, was he there?
14 A I don't know.
15 O How about Mr. Croneberger?
16 MR. BLAKE: -Objection, the man has said he doesn't 17 remember who was there and you've continued to ask what about
! E this, what about that, he doesn't remember.
19 MS. BERNABEI: Okay, I am going to continue to go i 20 down the list.
1 21 BY MS. BERNABEI:
l 22 O Mr. Croneberger?
l 23 MR. BLAKE: Obj ection, I regard it as badgering the 31 witness but you can continue, okay.
25 BY MS. BERNABEI:
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9 1 Q Mr. Croneberger?
2 A I don't know.
3 0 How about Mr. -- Mr. Croneberger was the person you 4 reported to, is that correct?
5 A That's correct.
6 Q And you don't remember if he was at that meeting?
7 MR. BLAKE: Objection, same objection.
8 A I swore to tell the truth, the whole truth and nothing 9 but the truth and I don't remember, that's all there is to it.
10 BY MS. BERNABEI:
11 Q How about Mr. Capadonno am I pronouncing his name E right?
4 13 MR. BLAKE: Same objection.
14 MS. BERNABEI: Mr. Blake, .I would prefer -- I assume 15 that you have a standing objection, I don't think you need to 16 state it.
17 MR. BLAKE: I think yesterday you instructed me that.
E if I have a problem I should object and I have a problem and B therefore I'll object when I regard questions as objections.
20 MS. BERNABEI: I understand you have an objection to 21 each of the persons I'm going to mention so I don't-think you Z! need to repeat it.
23 BY MS. BERNABEI:
24 _Q Mr. Lentz, was he at that meeting? We're talking 25 about the first meeting at 9 a.m.
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10 c 1 MR. BLAKE: Same objection.
2 A I don't know.
3 BY MS. BERNABEI:
4 4 Q How about Mr. Lehman?
5 MR. BLAKE: Same objection.
^
6 A I don't know.
7 BY MS. BERNABEI:
8 Q You don't know anybody else at that meeting?
9 A I have no recollection.
10 MR. BLAKE: Same objection, also asked and answered.
11 BY MS. BERNABEI:
- E O What was discussed at that meeting?
13 A The initial reports from Three Mile Island as far as j 14 what had happened out there, the transient that morning.
15 Q Did you take any notes during that meeting?
16 A Yes, I did.
17 Q Now, from whom did you receive the reports from 2 Three Mile Island?
B A Again, I can't recall who was in charge of the
- 20 meeting; whoever who had called the meeting gave the reports 21 but I can't recall who it was.
22 Q' Okay, and'you were taking. notes apparently what 23 someone said at the. meeting?
St A - That's correct.
25 Q Were you yourself_ speaking to anyone'at the site
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11 1 during_that meeting?
2 A No, I don't recall any contact with the site during 3 the meeting.
4 Q So basically someone at the meeting however was 5 talking to the site, is that correct, during the meeting?
6 A My recollection, I can vaguely recall the meeting 7 and I don't recall there being any conversations -- if there 8 was any conversations going on with the site during these 9 meetings it was outside of t,he room I was_in. I did not 10 overhear or vesdtaware of anybody talking to the site at that 11 time.
E Q Now, who gave you the information that you recorded 13 in your notes?
14 A It was whoever was talking, I can't recall who it 15 was.
16 O Now, was it clear that whoever it was that was 17 speaking at the meeting had previouslyftalked to individuals-18 at the site?
B A Well, I'm not sure if it'was an individual or if they 20 were getting it from somebody.else who had talked to the site.
21 -Q Okay but somewhere down the line someone had talked 22 to the site?
23 A Someone had talked to the site.
24 Q Now, do you know that the person whoever it was who 25 had talked to the site had spoken to someone in the' observation l
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12 I center or someone in the control room?
2 A No, no way of knowing.
3 Q ., What you knew was that someone who had originally 4 gathered this information talked to the site?
5 A It was conveyed to me that they had this information 6 from the site.
l 7 O Just to make sure I understand you, you do not know 8 who at the meeting was giving you the-information you put in 9 your notes? .
10 A That's correct, I don't recall.
11 Q Do you know who at the site had provided the E information to whatever individual was giving you the infor-13 mation?
14 A No.
15 0 You had no idea at all?
16 MR. BLAKE: Objection, asked and answered.
17 BY MS. BERNABEI:
18 O Do you have any idea?
i-19 A No, I don't.
20 Q -In taking your notes did you have any. sense that it 21 was in fact someone who was familiar with the situation at 22 the site who gave you the information, you meaning Parsippany?
23 A What do you mean familiar with?
24 Q -Did the person who provided the information you 25 . copied down know what was going on at Three Mile Island?
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13 1 A Well, to the extent that he had that information, yes.
2 Q So you assumed or your understanding was at the time 3 that it was someone who-had familiarity with the transient 4 that was then going on at TMI-2, is that correct?
5 A Well, basically, you know, they were familiar with 6 the knowledge they had at that time, right.
7 Q Did you have any reason to believe that any of the 8 information that you recorded at that meeting was inaccurate 9 in any way or unreliable? ,
10 A I had no basis for that.
11 Q No basis for thinking it was inaccurate or unreliable 1 D A No.
13 O What instructions were you given at that meeting 14 regarding taking notes?
15 A None that I can recall.
16 Q Is- it fair to say that someone superior to you had called 17 that meeting?
18 A Correct, I did not call the meeting.
19 Q 'And just talking about the universe of people who may 20 have called it, would it be someone in the sort of the line of 21 command that we outlined, that is Mr. Croneberger, Mr. Wilson 22 and Mr. Arnold? <
23 A It would have had to have been someone in that chain Si that called it.-
25 Q Now,.other than these three persong who was in that
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14 1 chain'of command?
2 A You mean in between them?
3 0 What I'm trying to do is get the universe of persons 4
who could have called that early morning meeting.
.5 A I guess the only other individual I can think of 6 would be Bob Keaton. .
7 Q What was Mr. Keaton's position at that time?
8 A I believe to the best of my recollection he was the 9 manager of projects or something similar to that.
10 Q Now, to whom did he report?
11 A I don't recall the organizational chart back in those E! days. Frankly I can't remember whether he reported to Wilson 13 or to Arnold, I can't recall which one.
14 Q Okay but one of the two of them?
15 A He would have fallen in that chain somewhere.
16 Q And other than those four individuals there was no 17 one else above you that would-have called this meeting, E essentially that's your memory?
19 A Nobody else I can think of right now.
20 Q Now, I assume that at least one of the individuals
-21 who called the meeting -- well, whoever it was was at the-22 I meeting, is that fair to say?
23 A Somebody might have directed somebody else to call !
.M the meeting.
l 25 Q No, what.I'm asking you is a.different question. i l
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19 1 Whoever called the meeting, I mean this universe of superiors, 2 that person was at the meeting, was he not?
3 A That's what I say, somebody may have called the 4 meeting --
5 MR. BLAKE: Objection.
6 A -- and then have been on the phone and sent somebody 7 else, I don't know.
8 BY MS. BERNABEI:
9 0 You were not the highest ranking official at that 3
10 meeting, were you?
e . . . .
11 A No.
U Q So at least in terms of the'se four people regardless -
13 of whether he called the meeting, one of th'ose four individuals , 'l 14 was at the meeting?
- 15 A ' Circumstances would say, yes, that it had to be one '
r 16 of those -- at least one of those four there. ,
17 Q What dis'cussion occurred at the m~eting? e .
2 A It was the presentation of the basic facts that they
- \
19 may have been able to learn up to tnat point in time about 20 -what had happened at Three Milo Island. ';
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21 Q How many people,qavefthe rp 'resentation, if you can I' ';-
22 remember? 4
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23 A I suspect it was -- I don't remember. '
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24 0 One, more than one, I'm just trying to get a ball ,
25 park figure. +; )~
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- A 1 I have just vague recollections of it, I can't-really --
I'm just asking you what is your best memory, I
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'3 understand'it'was a long time ago.
4 A .That's what I'say, I can't recall.
. -5 Q Was it one person.or more than one person?
6- A It had to be at least.one obviously. I can't recall y 7 if there was a second or not.
8 Q 'So it could have been more than one person who gave
! 9 the presentation?
1(L A It could have been, yeah.
1 1
11 Q Now, this presentation basically. consisted of the E facts that you took down in your notes, is that correct?
- i 13 A The notes are a better recollection of what 14 happened than my memory.
15 Q 'I understand. I'm just'trying to understand what
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16 happened at the meeting.
, l-17 ' A I would suspect that my notes reflect what happened
- 2 there. )
i 7f, r, B Q Now, how many people were at the meeting?
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'2i -A I have no~ recollection.-
i 21 Q Can you give me a ball park figure; are we talking Zt - about one other person than yourself, three other people, ten 20 ' people? I'm.just trying to get an idea.
,t 24 A. It wasn't one, two or three but beyond that I can't l 4
25 really recall.the number of people.
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17 1 Q At least four people at the meeting, maybe more? !
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2 A That's correct.
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3 Q So first of all, was there any introduction to the x
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. meeting, what you were all doing there?
4 Did somebodycsay we 3 had a transient at Three Mile Island-2?
6 A I'd have to look at my notes to see how it started 7 off, that would,be a better reflection. T' '
8 MS. BERNABEI: I'll mark thir, as Moore Exhibit 1.
9 For the record, it's a document which ' consists first of a handwritten cover page of the notes -- unidentified note.
10 i :
11 Second page memorandum dated September '17, 1930, from Mr.
u Wallace to Mr. Arnold titled internal' work related to GPU's a knowledge of core damage following the TMI-2 accident. The e ] t portion that we're going to be spending time on is I believe 14 i
15 it's approximately ten pages of, handwritten notes which have
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16 been identified by the company as having been w'ritten by lir.
17 Moore. There's a subsequent enclosure attachment which is \
a numbered file 2359.4, firstpageo,f(.whichissbated.coredamage/
19 fuel uncovering.
1 20 Third attachment numbered file 2359.4 an inter-office 21 memorandum dated January 29, 1980, a memo to the. file from >
1 3
22 Mr. Keaton. AndthereisafourthattachmentwhichisidentIfiEd 23 as TDK-TMI -- TDR, excuse me -- TMI-115.
-M '(Moore Exhibit Number 1 marked.)
25 BY MS. BERNABEI: ,
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, n- 4 18 1 Q Mr. Moore, I'm basically going to-be talking to you 2 about your notes today.
3 A Okay. ,
4 Q Fir ~st of all let me ask you have you ever seen either 5 without -- with or.without the first page the memorandum to 6
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Mr.tArnold and .
N the attachments which has been labeled as 7 Moore Exhibit 17 8 A' I have never seen that before.
9 O Okay, and if you would move on to the handwritten 10 notes and I would like you to review I believe it is ten pages 11 of handwritten notes which follow.
u MR. BLAKE: Do you want him to review all ten pages?
13 MS. BERNABEI: Yes.
); 14 BY MS. BERNABEI:
15 Q Can you identify those notes, that is those ten 16 pages of handwritten notes which follows the memorandum of Mr.
17 Arnold?
m A Identify _them?
19 Q Yes.
1 2[) A Do you mean they're mine?
21 Q Yes.
22 A Okay, that's my handwriting except I notice one thing 23 here that says taken at Parsippany on March 28, 1979, that's 24 not in my-handwriting.
25 Q Do you know whose handwriting that is, sir?
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19 1 A No idea.
2 MS. BERNABEI: For the record, that would be the 3 third page of Moore Exhibit Number 1.
4 A And this note at the top here received 1800 hours0.0208 days <br />0.5 hours <br />0.00298 weeks <br />6.849e-4 months <br /> 5 5 something 1979, that's not my handwriting either.
6 BY MS. BERNABEI:
7 0 Okay, but everything else which appears on those ten 8 pages are in fact -- were in fact written by you, is that 9 correct?
10 A Correct.
11 Q Okay, starting with pages 1 and 2 they are numbered, u well at least the second one, 2, is that correct?
13 A That is correct.
14 Q Are these the notes pages 1 and 2 which you took 15 at the early morning meeting you just described?
16 A That's correct.
I'7 Q If you can starting at the top,.TMI-2 transient, B you can read since the copy you rjeeived is somewhat 11-m legible, read the first five lines that is that portion which 20 you wrote.
21 A Loss of instrument air or malfunction /J-- it would api ear-22 to be instrument air system. How many lines did you say?
23 Q The first five.
M A Valves on condency polishers closed. Feed pumps 25 lost suction - initiates-emergency feed water. Unit trip
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20 1 (- .I believe that says includes or either that or it probably 1
2 says initiate, init- initiate reactor scram) turbin doesn't l
3 . trip on loss of feed water so scram would have occurred first 4 per Gary Broughton.
5 Q Okay, stopping there for-a moment, Mr. Moore, just l 6 stop there for a second. Those appear to be the notes for the l
top portion that is prior to the line, is that correct, .the 7
8 notes you wrote?
i i
l 9 A That's correct, except the middle lino anyway.
10 0 When you took these notes, what kind of paper did 11 you use; were you using a legal pad, a yellow pad?
E A No, a notebook; just a notebook, yellow or white 13 notebook paper. v 14 O And was that contained in a binder, it looks like 15 there's clips on the side or holes on the side?
16 A It would have been in a notebook.
17 0 In a notebook. Now, is this first page as it appeared 2~ at the time you took it,-in other words, or are these B basically' notes that were compiled from several different i
l 20 pages? Do'you understand what I mean?
21 A No, this was just as taken at the meeting.
22 O So what appears as-page 1 of your notes, that is 23 i
page 3 of the exhibit, is a page in your notebook as it appears?
M A That's correct.
25 0 And that would include the lines that appear in the
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21 1 middle?
2 A No, those lines look like some artifact of the l 3 xerox machine to me.
4 Q Okay, but at least the layout of all the pages are f 5 as you wrote them that day? In other words, they weren't 6 cut and pasted or something of that sort. These are the layout I
7 of the pages as you wrote them on March 28?
8 A In looking at them I would judge that this is the 9 sequence. They'ne loose pieces of paper so they could have come 10 out of order but it would appear to be in the proper order.
11 Q Okay, I guess I'm asking you a little different n question. For instance, is page 1 a page as you took it down 13 or is it in fact a compilation of more than one page?
14 A No, this is a copy of the original page as written.
l 15 Q Do you know where your notebook is, that is the
! 16 original of these notes?
17 A No.
E Q Did you at some time turn it over to your attorneys 19 to your knowledge?
20 A Not to attorneys, no.
i l 21 0 Who did you turn it over to?
! 22 A We had'some people assigned for accumulating 23 documentation after the accident and I turned it over to them.
M Q Okay, so that would be the internal GPU investigation?
25 A I don't know whose-investigation, they were trying to 1
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- 1- compile all the documentation.
2 O Would that be Mr. Walsh or Mr. Walls do you remember?
j 3 A No, it would not have been either one of them.
4 0- Do you know who it was, was it Mr. Keaton?
5 A It would not have been him either..
6 Q Mr. Long? Well, this is part of the long investigatic n, 7 I'm just trying to in general find out what's going on.
8 A All I know is there were people assigned to make 9 copies. I believe Bob Long was somewhere a part of that~
10 organization. Whether I turned it over to him or someone else, 11 I don't recall.
i n Q I'm just trying -- there was a long record kind of 13 inquiry and I'm just trying to find out if this was part of 14 that, you turned over your notebook, if that was --
15 A I don't know if it was part of that. All I know is 16 that we were acked -- whatever information we had to. turn it 17 over to some individual and that's what I did. '
2 Q And you know Mr. Long was involved in tnat effort, ,
a whatever?
20 A Yeah, he was over there someplace doing something.
il Q. Okay. -You no longer,have possession or control of 22 the original of these notes, is that correct?
23 .A Of these notes, no.
24 Q Now, the indication aga'in this would be --
25 A To my recollection, I've got some original notes but
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23 1 I don't believe these are part of them. They gave me back some 2 originals and some copies. I don't believe the originals are 3 'Part of what I've got.
4 0 Do you have any original notes from March 28th 5 through March 30th, 1979?
o 6 A .You mean notes of the events and that sort of thing --
7 no -- or do I, let's see what I-have.. They did return the 8 notebook to me and it had some xeroxes and some of the l
l 9 originals, I don't know which I've got.
10 0 okay, could you check on that to see if you do have 11 the originals of any of your notes? I mean after discussing u it with your attorney.
13 A I know I have some originals of some calculations it and stuff but as far as interviews and that sort of thing, I 15 don't believe I have. These pages here I don't believe I have 16 the originals of any of these pages here.
17 MS. BERNABEI: Could you just check and see and Mr.
18 Blake, I'll ask you if Mr. Moore might have any notes that the 19 GPU has not otherwise produced --
20 MR. BLAKE: Let's understand the question, I'm not l
21 sure that was the question.
22 MS . BERNABEI: The question to him was whether he 23 had any original notes'and I would like to see the originals 34 if you have access to them, that is if Mr.-Moore has or GPU 25 has.
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r 24 1 14R . BLAKE: You would like to see them if they're 2 within the --
3 MS. BERNABEI: Your possession and control, right.
l 4 MR. BLAKE: -- within the proceedings.
5 MS. BERNABEI: That's right.
6 MR. BLAKE: I'm informed that Mr. Moore had the notes
! 7 and that they've been reviewed and none of them bear on the 8 subjects in this proceeding other than the ones which have been l 9 produced already by the company in the course of discovery.
l 10 MS. BERNABEI: And I think I requested at one point
- 11 that you describe those documents or at least some of the u documents that you are saying are not relevant.
13 MR. BLAKE: Describe all documents which were not 14 given you because we regard them as irrelevant?
15 MS. BERNABEI: It seems to me that notes taken
- 16 contemporaneously with the first day of the accident may very 17 well be relevant and --
m MR. BLAKE: I don't know that'there were any of these 19 notes taken on the first day of the accident which we have not 20 produced.
21 MS. BERNABEI:- Okay, on the first three days?
22 MR. BLAKE: I don't know the answer.
23 MS. BERNABEI: Well, we don't have to argue about 2; this now but I would like you to check and represent to_me 25 whether or not there are any of Mr. Moore's notes that were
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1 taken on the first three days of the accident which you are
~
[ 2 withholding on grounds of relevance or what you're withholding t
3 period on any grounds.
(
l 4 MR. BLAKE: I understand your question.
i
^5 BY MS. BERNABEI:
i l
6 Q Okay, the fifth line on this page states turbine 7 doesn't trip on loss of feed water so scram would have' occurred l 8 first per Gary Broughton, is that correct?
9 A Yes.
10 0 Okay, now that indicates, doesn't it, that Mr.
11 Broughton perhaps gave you the information that's contained u at least in the last part of that_ sentence?
, 13 A That turbine doesn't trip that would indicate that --
I l 14 per Gary Broughton would infer that he must have.
l 15 Q Okay, that would infer that at least that part of l
16 the information was given to you by Mr. Broughton?
! 17 A Well, the part that just starts off with turbine 18 doesn't trip, yeah.
l 19 Q Now, it. appears that.these notes -- were all-the 3D notes -- let me start back a bit. The notes on these two pages 21 were all taken at that early morning meeting?
i . 1 L 22 A Well, the first two pages? t 23 Q The first two pages.
24 A Well, you know, when you get to these adlibs on the 25 end there,_I don't recall, you know. That'might have been l
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26 I something that was added later, it doesn't flow with the rest
! 2' .of it so~it's hard for me.
l 3 .Q You're talking about adlibs, the last two lines?
l l 4 A No, I mean, like on this one here I've got unit trip 5 instrument air per -- you know,' initiate reactor scram. After 6 that I've got.these little notes on the side.
7 Q It seems to be addendums to which you originally 8 wrote?
9 A Right, and I don't recall whether those were written -
10 down at that moment or if they were afterwards or exactly when I 11 that occurred.
- n Q Okay, but it would have-been in.the general time j 13 frame in the morning of March 28th, whether at'the meeting or 14 not?
15 A Yes.
16 Q Okay. And is it'likely they would have been taken 17 or would have been added whether or not at the meeting sometime 2 prior to your next set of notes which start at 10:05 a.m.,
19 that is the third page?
20 A Prior to or at? I 21 l Q Or at the_ time of, yes. In other words, they would
[
22 have been taken though in the general time frame in the early j 23 morning --
l l
24 A In the early morning,-yes.
l~
25 Q And at least that bit of information we know came from l
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27 1 Mr. Broughton? -
2 A Right.
3 Q Most of this is pretty legible. Can you read for us 4 the first line which appears to have an addendum or what you 5 called an adlib both on the left side and the right side and 6 again we're on page 3 of Moore Exhibit 1 7 A I can't make that out, something -- is yours any
[
8 more legible than this one? i
- 9 Q I think you've got our best copy. It says something l 10 about heat open --
11 A Oh, that one up there.
j u Q Heat open? Something about that?
l 13 A Did -- I hazard to guess what that second word is, 14 something hang open.
15 Q Now, if I'm correct, it says high pressure or high i
16 pressed pressure in RC reactor coolant system, is that right?
17 A Right.
l 18 Q Lif ted electro- and safety.
19 A Right.
2D Q Electro meaning?
21 A Electro magnetic -- electromatic, I'm sorry.
I 22 Q Okay, now, there's also handwriting or an addendum 23 on the right. Could you read that for us?
! St A' Would blow quench tank rupture disc.
Y) Q Now, if you.had reviewed the last portion of page 3 l
l
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l' f 28 l 1 of the exhibit, the first page of your notes, were these to
! 2 your memory given to you by one person at this meeting? In j 3 other words, this was all given to you during the presentation? .
4 A That's like I say, I can't remeroer, you know. My 5 vague recollection, it was an individual relating what had l 6 happened.
7 Q Okay, moving onto page 2 of the notes, page 4 of the 8 exhibit. Okay, this is a continuation of the presentation of g the individual relating what had happened at least down before !
1 10 you get to the last two lines on that page.
l 11 n Right.
l u Q There's a series of questions which appear on page 2, 13 is that correct?
! 11 A Correct.
15 Q Okay, now, who was posing these questions?
16 A I don't know. ;
{ 17 Q In other words, was this part of the same person who i
j u was giving this presentation to you? Was that person posing l 19 the questions or --
20 A i
That's what I would have to infer from the notes.
21 Q Now, what discussions if any were there about either 22 the conditions which were related to you which appear on page 1 23 or the questions which are asked on page 27 l m A I don't recall the discussions. I recall it was l 25 just basically a presentation. If there had been a discussion,
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i i
SQ l
1 I probably would have documented it. I think what you see here 2 is what happened.
3 Q Okay. Now, what was the purpose of these questions, 4 the questions posed on page 27 5 A I don't know.
l 6 Q Were they questions to individuals in the group?
7 MR. BLAKE: Ms. Bernabei, I have to object. Mr.
8 Morris said the notes teere a better recollection of what it was 9 that he might have had. Apparently from the host of questions '
10 which you've asked and a probe from each angle, he has no
!! independent recollection. He has reviewed his notes, he's u answered to the best of his recollection. We're using 1
13 valuable time here and we're on a tight schedule of depositions!
It and I regard those as not necessary.
15 MS. BERNABEI: I'm trying to get into the context of 16 how the notes were taken and what was going on.
17 BY MS. BERNABEI:
M Q Mr. Moore, do you remember to whom these questions l
l 19 were posed; were they posed to the individuals in the group?
20 A I think this was a state of reflection of a state l 21 of knowledge as opposed to or a lack of a state of or a lack 22 of knowledge.
23 Q So these were basically in the context of conditionc that-24 these were questions people didn't know the answers to at the i 25 time?
I:
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30 1 A I think -- right, questions people would like to 2 know the answers to.
3 0 And who wanted to know the answers to those questions?
4 A I don't know who. Like I said, I suspect it 5 reflected the state of mind of the gathered peoplo thoro.
6 Q Okay, so it's fair to say that these wore questions 7 of whoever was in that group, that is the group of people?
8 Those wore the questions that the group wanted the answers to?
9 A Like I said, I don't know. Probably somebody 10 summarized what they thought noodod to be known.
11 Q Now, did you take any assignments or responsibilities u out of that meeting; that is, what woro you supposed to do when 13 you left that meeting?
11 A According to this I was supposed to como back again 15 at 11: 30 a.m. .
16 0 Okay, and that's the note meet again at 11:30 a.m.
17 at the bottom of the second page?
18 A That's correct.
i 19 O Now, it also says RFW will contact plant before
- 3) anybody goes out to TMI, in that correct?
21 A That's correct.
Z1 0 That's Mr. Wilson?
Z1 A That would be Mr. Wilson, right.
21 Q okay, Mr. Wilson apparently if someone from Parsippany 25 was to go out to TMI was to contact them before anyone from
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I 1 Parsippany went, is that correct?
2 s A Dick Wilson was going to contact somebody at Three 3 Mile Island, right, or if anybody was departing for Three Mile !
i 4 Island.
! 5 Q Was there a discussion who, if anyone, from Parsippany l 6 would go to Three Mile Island at that time?
j 7 A The notes don't reflect anything of that naturo.
l 8 Q Okay, but there at least was the consideration that +
9 might occur in the future, is that correct? i 10 A That's what the notes would reflect. !
)
11 Q Now, what did you do after this meeting, if you can u remember?
l 13 A I don't recall.
Il Q How long was the meeting?
l 15 A I don't recall.
l 16 Q Okay, reading those notes, how long would you evaluate l 17 that kind of a meeting took? I guess my question is to you
/
l 2 knowing yourself as a notetaker, was this a 15 minute meeting, 19 a half an hour meeting, an hour meeting?
30 A I really can't judge f rom notes.
21 Q Well, it's fair to say it took more than 10 - 15 22 minutes probably, is that fair?
21 liR. BLAKE: Ms. Bernabei, it's not fair to say
( 24 anything. The man does not remember and he has said so and 25 that's his testimony. I object to questions of that type, j
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32 1 Itading and bhdgering and trying to --
! 2 MS. BERNABEI I'm not badgering him, I'm trying to i
i 3 jog his memory.
4 MR. BLAKE: Leading him into saying something he i 5 doesn't recall. -
6 MS. BERNABEI I'm not trying to badger him.
7 BY MS. BERNABEI:
8 0 What I'm asking you is, do you --
9 A I honestly don't remember.
10 Q Okay, there was another meeting at 10:05 or so?
11 A Yeah, I got the second set of notes here, 10:05, u right.
l 13 0 Now, between the time of the first meeting that Il started at 9 and extended for an undefined period of time, and
! 15 this meaning at 10:05, did you speak with anybody?
16 A I have no recollection whatsoever of that time frame.
17 Q So you can't remember if you did anything?
- 18 A No.
19 l Q Do you remember these meetings being back to back, 30 that is the first meeting and the second meeting at 10:05? I 21 mean did you walk out of one room or did you have two meetings 22 in the same room or were they very close together?
23 A My recollection is that -- and it's rather vague --
24 that they were in the same room but, you know, the time between
%k them I don't remember.
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1 Q Okay. Now, who was at the second meeting?
2 A Let's see, the notes indicate that it was Keaton, l
l 3 Croneberger, Broughton, Capadonno. Lentz, myself and Lehman.
! 4 Q Now, is it fair to say that Mr. Keaton would be the
$ highest ranking company individual in this meeting?
l 6 A I don't recall what the relationship -- like I say,
! 7 I can't recall where Keaton fell exactly in the hierarchy at that l 8 point in time but I would say Keaton and Croneberger were 9 probably on an equal level.
10 Q And they were the two highest ranking officials in 11 this meeting at 10:05 a.m.?
U A That's correct.
13 Q Is it likely then that the meeting would have occurrec 11 in one of their offices?
15 A My recollection is not that.
l 16 Q Was it held in a conference room?
! 17 A Like I say, it's very-vague but as I recall it was M some sort of a conference room.
! 19 Q And is it fair to say that Mr. Keaton and Mr. Crone-20 berger being the two highest officials at the meeting one of l 21- them would have called the meeting -- one of them or Mr.
22 Arnold?
j 23 A Somebody in that chain of command called it, I can't 24 say who. Somebody, whoever had the first one, said come back l 25 at 11:30 but somebody obviously got the word around come back
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34 I sooner than that so --
2 0 Okay, but what I'm asking you is just in terms of l
3 corporate Protocol. It would have been one of the -- -
4 ~A Somebody from Arnold on down through to either Keaton j 5 oor Croneberger, right.
6 Q All right, so it would have been Mr. Arnold, Mr.
! 7 Keaton, Mr. Croneberger?
8 A Semebody in that, right.
! 9 Q And essentially it appears that although a meeting 10 was next scheduled at 11:30, someone of those three individuals 11 said we should do it earlier at 10:05 a.m.?
E MR. BLAKE: Objection.
13 BY MS. BERNABEI:
14 O That's pretty much what you said, am I characterizing 15 correctly?
16 MR. BLAKE: He is not limiting it to those three, l 17 he said somebody in that chain. Previously he's identified '
I 2 Mr. Wilson as also being a portion of that chain. He hasn't a limited it to those three people calling this meeting,Eit's l
20 just not fair for you to characterize his prior testimony that l 21 way --
22 MS. BERNABEI:
I Mr. Blake, I would appreciate it if m you didn't have talking objections, if you would state your Si objection. I don't think it's right to signal the witness.
25 MR. BLAKE: My objection is that you have
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r r., -
35
.1 .mischaracterized the witness' prior testimony and you used 2 'that mischaracterization to ask him a subsequent one.
i 3 BY MS. BERNABEI:
4 Q Okay, let me ask you, Mr. Moore, is it fair to say r-5 'that given the list of attendees at the meeting, Mr. Croneberger 6 and Mr. Keaton, and.given the corporate protocal at the time 7 of this meeting on March 28, 1979,that either Mr. Arnold,.Mr.
8 Keaton or Mr. Croneberger would have called that meeting?
'9 A What I said was somebody in the chain of command 10 from Mr. Arnold down through there would have called it.
l 11 Q Who did that chain.of' command-include?
E A That's what we went over before, it was Bob Arnold, 13 Dick Wilson, Keaton, Croneberger and there might have been 14 others, you know, there were other people at an equal level 15 but somebody in th,at chain of management at that point in time.
16 Q Would Mr. Wilson call a meeting and not be at the 17 meeting? '
18 A I don't know.
l!L Q Have you ever known him to.do that in the past? I'm l 2D just asking about your experience with Mr.. Wilson. Would.he 21 have called a meeting and not himself shown .up at the meeting?
22 A- He could have told people to have a meeting..
l 23 .) No, my question to you'is did.Mr. Wilson in your i 24 experience ever call a meeting of individuals at this level of 25 the:corporationLand not himself show up at the meeting? I'm
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36 1 asking about your experience.-
2 A You mean call a. meeting as though he was going to be 3 there and then we sat and waited for him?
4 O' No, I'm asking has Mr. Wilson to your knowledge and i
5 your experience at GPU Service. Corporation or any other 6 subsequent corporations ever called a meeting of individuals of l 7 this level in the corporation and not himself shown up at the 8 mooting?
9 A I don't recall anything like that.
10 Q You don't recall, okay. Is it fair to say that i
11 whoever called that meeting earlier than previously scheduled l t! was either Mr. Arnold, Mr. Keaton or Mr. Croneberger?
13 A I couldn't say that. I don't know for a fact that 14 Mr. Wilson didn't call it, I don't know who called it.
l 15 .Q Is it fair to say it would have been one of those i 16 four individuals, right, and you thought it was one of those 17 three individuals before Mr. Blake's intervention?
18 A I didn't think that, maybe you did.
l 19 MR. BLAKE: Ms. Bernabei, there's no call for that.
20 There's no call for such an observation.
21 BY MS. BERNABEI:
22 Q In any case, the meeting was called earlier than l 23 previously anticipated, is that correct, by someone?
24 .A That's what my notes reflect. My first notes 25 reflect that we were to meet again at 11:30 and second set of i
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17 1 notes reflect 10:05, so that's -- it would appear that's --
2- Q What was Mr. Capadonno's position on March 28th?
3 A As I recall he was a_ manager of mechanical systems.
4 Q Did he report to you?
5 A No, he would have reported to Don Croneberger.
6 0 Was he on the same level as you?
l I 7 A That's correct.
8 Q- How about Mr. Lentz e what was his position?
9- A I don't recall exactly what his position was at that 10 point in time. I believe he was working out of our office but 11 I don't recall his exact position.
U Q Do you know generally what his duties were, not his 13 exact position? How did he function in the corporation?
14 A At that point in time, I really don't remember what i
15 his duties were.
l l
16 0 Your answer suggests that perhaps he was not part i
! 17 of the GPU Service Corporation?
! 2 A No, he was part of the GPU Service Corporation but B at that point in time I can't recall what his position was 20 within the company.
l 21 Q He had a technical background,_did he not?
22 A That's correct.
- D Q Do you know what kind of technical background?
t 24 MR. BLAKE: Ms. Bernabei, I must object. I mean, 25 you have lots of information about these people that has been
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38 i
1 Provided to y6u in the course of discovery.
2 MS. BERNABEI: Okay, I'll move on.
3 BY MS. BERNABEI:
l 4 Q Mr. Lehman --
5 MR. BLAKE: We have a fairly tight schedule and I 6 think you're wasting a lot of time.
7 BY MS. BERNABEI:
l 8 Q Mr. Lehman, what was his position at that point in 9 time?
10 A He's an engineer. Exactly what his exact area of 11 responsibility, I don't recall.
- u Q To whom did he report, what level was he on?
13 A He reported to Gary Capadonno.
14 O So is it fair to say he was at a level somewhat below 15 you and Mr. Capadonno in the reporting chain?
16 A It would have been the next. level down. '
l 17 O What was discussed at this meeting?
M A My' notes appear that we were setting up at this B point in time to go out to Three Mile Island and assignments 20 were given as to what each individual was supposed to 21 investigate.
22 O Okay, and who made these assignments?
I 23 A Strictly by inference it would have had to have been 24 Keaton and Croneberger.
l 25 O Now, what was your understanding of the reason for
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39 1 these assignments? In other words, what was the information 2 going to be.used for that you found -- you meaning you in the 3 meeting?
.4 A Increase our state of knowledge.
5 Q I assume that would have been so that Parsippany or 6 the individuals in Parsippany would have a knowledge of what 7 was going on in the reactor to make any necessary decisions 8 about it. ,
l 9 A I don't know of any specific -- I'm not aware of any 10 specific intent of what was to be done with.it, it was 11 preceived me to become knowledgeable in these areas.
E! O In part was it not to serve as support for-the
! 13 individuals at the site, that is as technical support?
l 14 A I couldn't infer that from these notes.
/
15 O No, I'm just asking you generally, your knowledge.
16 .Was it in part that you people were supposed to go down there 17 whoever went down to provide technical support to the people B onsite?
19 A From these notes, I would judge that it was 1
20 independent of the people onsite it was to go and assess 21 the condition of the plant.
22 Q Okay, I'm just trying to jog your memory. Mr. Keaton 23 represented that in an interview with the NRC that he believed M that the team was assembled or identified in part to send as 25 support for the unit, do you remember anything like that being
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4 40 1 discussed?
2 MR. BLAKE: Objection, can we see a copy of Mr.
3 Keaton's representation or his statement?
4 MS. BERNABEI: I don't have it here, we can provide 5 it for you, Mr. Blake, if there's some problem with that 6 representation.
7 MR. BLAKE: If you would, please.
8 BY MS. BERNABEI:
9 Q Mr. Moore, can you answer that question?
10 A Would you testate it?
11 O Yes. Mr. Keaton said in a prior interview to the u NRC that in part this team of people, and I assume he's talking s
13 about the team of people listed in your notes, was assembled 14 in part to send as support for the unit. Do you remember 15 anything like that being discussed?
16 A Is he talking about these individuals that I've got 17 listed here or --
E Q He's talking about people that were sent from B Parsippany to the site.
20 A t what point in time was he talking about?
21 Q The first day of the accident.
l 22 A The people that were dispatched that actually went 23 there the first day or the people that came out later?
N Q The first day.
25 A That may have been on his mind, I don't know.
I -
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41 1 Q How did you see your role? In other words, is it s
2 fair to say that you're listed behind some of these categories 3 as data required, is that correct?
4 A That's correct, yes.
5 Q Okay, now what did you understand your role um to be?
- 6 A Well, like I say, my notes are a better reflection i
7 of what transpired than my memory at this point in time.
8 0 I'm asking you, Mr. Moore, let's stay away from the 9 notes for a moment. What is your understanding on that day of i
10 what your role was to be; what were you to do?
11 A Bascially go down and assess the conditions of the D plant with respect to these particular components that are l ,
13 listed there by my name.
14 O Okay, and specifically with regard to your name, it's 15 the steam generator, the reactor coolant pumps and the RC L
16 safeties and quench tank, is that correct?
17 A That's correct.
18 Q They would be items 4, 5 and 7?
19 A Yes.
20 Q Now, item 2, instrument air malfunction, that's to be L 21 handled by Mr. Croneberger?
i 22 A No, that would be Gary Capadonno.
23 0 And was core uncovered, that's to be handled by Mr.
24 Broughton?
l 1
25 A That's correct.
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l 42 l 1 Q Moving down to item 6, containment building, that's 2 to be handled by Mr. Murrell?
3 A That's correct.
4 .O And 9, radiation release, that's to be handled by 5 Mr. Wallace?
L 6 A- That's correct.
7 Q Now, was Mr. Wallace at this meeting?
8 A The notes don't reflect that he was, i
-9 Q But somehow Mr. Wallace was considered in the team 10 that was to gather data, is that correct?
11 A His name is identified here.
U Q Now, was this~ team, if I can call it a team, this 13 group of individuals, were they all or were'you all to be sent 14 down to the site to gather that information?
i f
15 A Well, I can't recall who exactly ended up going down 16 that day. I went as an individual. .
No, I'm asking you a different question. Was it l 17 Q
! 18 anticipated that the group of people assigned to gather a information would all be going down to the site, would that be 20, the idea?
l 21 A I don't know.
22 Q Okay, it was anticipated at least a portion of that 23 group would be sent to the site, is that. fair to say?
N A A portion did go to the site.
I 25 0 Okay, a portion did go to the site?
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1 A Yes.
2 O And who went to the site besides yourself?
- 3 A The ones that I can recall are Jerry Broughton, 4 myself, Rich Lentz went to the site.
- 5 Q How about Mr. Lehman?
l L 6 A I don't recall him being there, not that first day.
7 Q You don't recall Mr. Lehman?
l 8 A Not the first day. i 9 MR. BLAKE: He said he cannot recall Mr. Lehman .,
10 being at the site the first day.
11 BY MS. BERNABEI:
E O I'm asking about the first day, you don't remember 13 Mr. Lehman going down?
14 A No.
15 0 You said you went down as an individual, what did 16 you mean by that? You didn't go down because of this I
17 assignment? .
1 2 A Well, I went down because of this assignment. What 19 I mean, we didn't all hop in a car and drive down together.
- 30. Q Was it decided at this meeting, at the 10:05 meeting,
( 21 'that those individuals who would go to the site? In other wordsi, 22 did you get your assignment to go to the site at that time?
23 A That's correct.
l 24 Q And it would be true for Mr. Broughton and Mr. Lentz 25 as well?
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, 1 A I don't know, I presure-that would be correct.
t Q Now, for these items that do not have an individual's i
~3 name written by them, who was to gather data relevant to those 4 items? '
,j 5 , A I don't know.
I6 Q I assume it would not be the group of you who went 7 to the site, is that fair to say?
8 A I wouldn't hazard to guess that. It might have been somebody in the group,
- 9 i
10 O' To your knowledge were there any individuals outside 11 of the individuals at this meeting or the individuals whose 12 initials are listed who was to be gathering information for 13 Parsippany?
It A 1 don't know that these initials reflect that that 15 individual was to personally gather it. I wouldn't consider 16 this i<
to be an assignment or a responsibility to see that the 17 information was gathered.
18 0 okay, maybe I stated this a little wrong. Other than 19 ' the individuals listed here, was anybody. responsible to gather a that information?
21 A I don't know.
21 Q I'm not talking about people directed by these 21 individuals, I'm' talking about --
24 A 1 don't know. I understand what you mean but I don't 25 _know if there was anybody else that had assignments or not.
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45 1 Q At least this'is-in terms of the assignments you were 2 familiar with, this is the universe of people, that is the 3 people listed as the attendees of the meeting?
4 A Well, these are the people who were at the meeting 5 that are listed at the top and the initi$1s reflect'whh was 6 given responsibility for gathering certain information..
7 Q Now, is it fair tofsay that some of the people 4
4 8
whose initials are not listed but who were attendees at the 9 meeting were also given responsibilities-to gather information?
10 A Run that by me again, 11 Q Sure. There's a list of attendees at the top? i
^
E A Right, i
[ 13 Q Now, some of thos'e people's initials do not appear, 14 in other words, theyapharentlyweren'tgiven_ specific-15 assignments at the meeting. I'm asking you, did they have 16 responsibilities to gather information? I'm_n'ot asking you 17 from the notes, I'm asking you if you have any ---
18 A Like.I say, ,I dob't' recall any assignments for any t-19 of those people. "1 20 Q. Okay , rune, did anyone at-that. meeting or had anyone I
i 21 at.that meeting spoken to Mr. Arnold. prior to or_during l 22 the; meeting?
23 A I don't know.
24 O Did'anyone indicate that Mr. Arnold knew that this 25 Jgroup was meeting?
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46 1 A I really don't know.
2 0- Well, is it fair to say your understanding at the 3 time was -- was Mr. Arnold at this meeting?
- 4. A- There's no indication that he was.
5 Q Mr. Moore, do you know that you took these notes.for 6 a fact, that these are your notes?
7 A Yes, that's my handwriting, definitely my handwriting.
8 Q And is it your practice to list yourself in the 9 attendees at a meeting which you attend?
10 A Yes.
11 Q And you list yourself in the middle and not at the
[ u end or the beginning?
13 A I don't know. Sometimes I just go around.the table 14 and start at one point.
15 Q Okay, at the second meeting did you have any notes 16 with you? That.is, did you have your earlie'r notes or any 17 other pieces of paper?
18 - A I don't know. I presume my practice would have been 19 to have my first notes with.me. 1 20 : O There is testimony from Mr. Wallace that he was in ;
l 21 a meeting with you sometime in the morning around or possibly 22- 'Ifthink the early afternoon which~you had certain notes with
- D - you.
7A A In a meeting --
25 MR. BLAKE: Do you have a copy of Mr. Wallace's
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47 1 statement that you're making reference to?
2 MS. BERNABEI: It's his B and W deposition.
3 MR. BLAKE: Do you have a copy of it that you can r
- 4. show the witness?
5 MS. BERNABEI: I'm not sure we have right now, if 6 you'd like to, I can show you, Mr. Blake.
7 MR. BLAKE: Well, I would just ask if you're going 8 to refer to that and try to use it for questioning then --
9 A What period of time was this?
10 BY MS. BERNABEI:
11 Q Late morning, early. afternoon.
E A What's' late morning?
13 0 10:00, early afternoon, 12:01 14 O It couldn't have been 12:01.
15 Q Because you were gone by then?
16 A I was gone by then.
17 Q Do you remember any meeting with Mr. Wallace in the a morning?
19 A Like I say, the notes are the only thing. I can't 20 recall the individuals involved in the meeting, just what 21 my notes reflect,'it's too long ago. <
Z! O -You have no memory that Mr. Wallace was in this 10 a.m .
23 meeting?
}
St A I have no recollection of who was there other than i
25 what the notes = reflect.
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48 t
1- Q And'you have no recollection of Mr. Arnold beinga 2 at any meeting?
3 A No, I don't recall. Like I say, I can't envision
-- I can't picture the people at the meeting.
~
4 the people 5 Q Let me ask you this, did you have any other meetings 6 after this 10:05 meeting?
7 A Not to my recollection.
8 Q Let me represent to you Mr. Wallace --
maybe this 9 would jog your memory. He said that he remembers being --
10 MR. BLAKE: What are you reading from, Ms. Bernabei, .
11 his statement?
, n MS. BERNABEI: His B and W deposition.
13 MR. BLAKE: This is your notes of Wallace's B~and W 14 deposition?-
15 MS. BERNABEI: Yes.
16 MR. BLAKE: But you don't have'a copy of Mr. Wallace's 17 ' deposition?
18 MS..BERNABEI: I.may, and I'll provide it. Do you 19 want to take a break, we can do that and you can review it.
m MR. BLAKE: 'Why don't we do that.
21 MS. BERNABEI: I'd like to ask the question, Mr.
22
'Blake, and then if you have some questions whether.it's fairly
\
m represented,-you'll have a chance-to question Mr. Moore, okay..
s I don't appreciate your interrupting his examination..
25 - 1m. BLAKE: Well, it's not normal practice that)you
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49 1 refer to somebody else's statement without offering an oppor-2 tunity'for the witness to take a look at it.
3 MS. BERNABEI: I am going to ask him his best 4 recollection. If he has some problems then maybe we can go to 5 the statement, okay.
6 BY MS. BERNABEI:
7 .Q .Mr. Moore, I'm going to ask you if this jogs your 8 memory, okay?
9 A Yes.
10 Q Mr. Wallace in the deposition in the GPU v. E and W 11 litigation, he stated that he remembers a meeting in Mr.
E Arnold's office and.you were there at the time he arrived and 13 that you had certain bits and pieces of data with you, okay.
14 You had some notes that included certain bits and pieces of i
15 data about what was going on at the site. -And that that 16 sequence was reviewed with you and other individuals in-the 17 group. And he stated that the following individuals-were'in a 8 group and he places this meeting in the early afternoon, okay, B although it's unclear whether it was 11 a.m. or the early.
20 afternoon; yourself, Mr. Ron Williams, Mr. Keaton, Bill Hertz 21 'and Mike Murrell. Do you remember any meeting of that descripticn 22 either in the morning or the early afternoon with Mr. Wallace?
23 lA No recollection at all.
N Q None'at all?
25 A -No.
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, 50 l 1 Q Do you remember any meeting in Mr. Arnold's office at 2 -any time prior to your going to the TMI site that day?
3 A I can't recall this -- I can't recall a picture in 4 my memory, no.
5 0 You can't recall any meeting in Mr. Arnold's of fice 6 that day?
7 A I can't recall -- I can vaguely recall meetings but 8 I can't envision where they took place, I can't-recall that.-
9 Q- Do you recall any meeting where Mr. Wallace was 10 present on that date?
A 4
11 Like I say, I can't recall which individuals were E present at the meetings and my notes are the only thing I've 13 got to go on.
14 Q Do you recall any meetings which Mr. Arnold was 15 present? Mr. Arnold was the highest ranking official at 16 Parsippany, is that correct?~
17 A That's correct.
B Q And you don't remember whether or not you had any B meetings with him present that day?
20 A I don't remember.
21 0 Well, it doesn't sound very credible. Let me ask 22 you this.
23 MR. BLAKE: It's rude of you to make that observation, 24 Ms.~Bernabei.
25 BY MS. BERNABEI:
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51 l I
1 Q Let me ask you, Mr. Moore, your testimony is you do 2 not know whether you met with Mr. Arnold on March 28th, 3 1979, prior to going to the site?
'4 A That's correct.
5 0 You don't remember?
6 A I don't remember.
7 Q Did you speak to him whether or not you met with him?
8 A I don't remember having spoke with him.
9 Q How about Mr. Wallace, you don't remember Mr. Wallace 10 either?
11 A I don't recall having spoken or met with him. He U may have been at the meetings, I can't say one way or the 13 other.
14 Q. Let me ask you this, Mr. Brown has testified, again, 15 this is in the B and W litigation, that he remembers a meeting 16 in Mr. Arnold's office with yourself, Mr. Keaton and Mr.
17 Lehman._ Do you remember that?' He remembers it in the late B morning in Mr. Arnold's office and that you were present.
19 MR..BLAKE: Do you have a copy of Mr. Brown's l
20 statement, one that you can show the witness?
21 MS. BERNABEI:- I do, I'd like to ask Mr. Moore.
22 A I don't recall specifically. These meetings here 23 may have been in his -- I don't know.
M BY MS. BERNABEI:
25 O There's been other testimony under oath, Mr. Moore,
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52 1 and I'm asking'you by Mr. Broughton who evidently was in this 2 group of people with whom you were meeting earlier as well as --
3 A I don't know if it was earlier or if he's referring 4 to this meeting here in fact. Maybe he was referring to this 5 meeting here. This meeting may have been in Bob Arnold's 6 office, I can't tell from the notes.
7 Q So it could have been that meeting?
8 A It could have been that meeting.
9 Q Now, Mr. Broughton has stated there was some discussic.n ,
10 again at that meeting, by Mr. Keaton about radiation levels, 11 do you remember any discussion in that meeting about radiation E! levels?
13 MR. BLAKE: Ms. Bernabei, I have"the same problem 14 with your asking questions --
15 A Which meeting are you talking about, this 10:05 16 meeting?
17 BY MS. BERNABEI:
18 0 10:05,.do you remember any discussion about: radiation 19 levels at that meeting?
20 A -Like I say, whatever is in the notes.
21 Q I'm asking you. I'm trying to figure if it's the 22 same meeting that Mr. Broughton testified to. You said maybe 23 it'was, maybe this meeting was in Mr. Arnold's office. Do you
.r M remember any. discussion about radiation levels in'this meeting 25 at 10:05 a.m.?
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53 1 A I don't recall anything beyond what the notes --
2 Q Do you remember any discussion about starting a 3 reactor coolant pump, again in this morning period?
4 A Well, one of the items listed under my name here for 5 checking into it why didn't the one merit coolant pump start.
6 Q Okay, so that may have been discussed. In fact 7 something.about a reactor coolant pump not starting was in 8 fact discussed, is that correct?
9 A That's correct, yes.
10 Q So, to the extent that the attendees at the meeting 11 are the same and that at least one of the items starting the a reactor coolant pump was discussed, it may have been the same 13 meeting Mr. Broughton testified to, is that correct?
14 A I don't know if it was the same meeting or not, it 15 could have been.
16 Q Were you at any other meeting with Mr. Broughton on 17 that day; Mr. Broughton, Mr. Keaton-and Mr. Lehman?
E a Like I say, these --
19 Q No,'I'm asking you,'Mr. Moore, were you at any other 30 meeting that morning?
21 A My memory is -- I don't remember being -- I can 22 remember a couple meetings and apparently these are-the ones 23 I've-got notes for.
24 0 .Did you take notes at-all the meetings you attended 25 that morning?
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54 1 A I don't know.
2 Q Is it your initial practice to take notes at meetings?
3 A Yes, it is.
4 Q Okay, so if you had acted as you normally do in your 5 usual course of business, you would have taken notes at those 7
6 meetings which you attended on that morning, is that fair to 7 say?
8 A In all likelihood I~would have, yes.
9 Q Do you have any notes from any meeting that morning 10 other than the two meetings you pointed out to us, that is the 11 one about 9:00 and the 10:05?
E ?. No notes, none other than these.
13 O So inferring from the usual course in which you take 14 notes during the meeting and the fact that you had no notes 15 for any meeting after 10:05, that-would lead one to infer that
~
16 you attended no other meeting, is that correct?
J 17 A I wouldn't -- maybe the notes were lost in the' 18 process of --
B Q Do you. remember-losing any notes?
4 20 A I don't remember losing any notes.
4 21 Q And you don't remember any other meetings after the 22 10:05 a.m. meeting, is that correct?
23 A I'have--no recollection of any~after that, that's M correct.
25 0 And your memory is that the meeting at 10:05 a.m. may
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55 1 have been in Mr. Arnold's office?
~
2 A I said my memory is I don't remember where it was.
3- Q But it may have been the same meetings which Mr.
4 Broughton talks about?
5- A It may have been.
l 6 Q Okay. Your memory is that at this meeting at 10:05 7 a.m. it was discussed and decided-that certain individuals 8 would go to the site to gather information, yourself being one 9 of them?
10 A I don't recall if the decision was made as to who I 11 was going to go as to who was responsible for making sure that u somebody did go. l 13 Q My question to you was a decision made or was l 14 consideration given to a decision to send certain people to the 15 site at that time?
16 A I don't know.
17 : O When was the decision made?
B MR. BLAKE: What decision?
19 MS. BERNABEI: To send certain people to the site.
f 20 A I don't know if it was a decision or a multitide of 21 decisions.
- 22 BY MS. BERNABEI
23 Q Okay, when were any of these. decisions made, if you M -know?
- 5 A In my case from my indication here, I was made
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56 1 responsible for determining which of these, you know, what the 2 status was of these three different items in the plant and i
3 whether I was directed to go to the island or left up to me 4 to determine who should go, I don't recall. I may have been s
5 responsible for it and decided to go myself or somebody may havc 6 directed me to go, I don't recall.
, Q To your knowledge, was any individual directed to go 8 to the island; that is to go to the island and find out what 9- was going on?
10 A I don't recall other than like I say what the 11 notes reflect.
u- Q The notes do reflect that certain individuals were 13 givel those assignments, do they not, I think that was your 14 prior testimony?
15 A Right, given the assignment to get the -- you know, 16 the responsibility for getting that information.
17 Q My question to you is-what individuals were given 18 an assignment-which necessitated their going to the site?
~
19 A Well, all of the majority of the people listed here 20 had people reporting to them so probably none of them were 21 necessitated to going to the site,-they could have.sent somebody 22 else.
23 -Q .Was anybody directed on March 28th'to go to the TMI Si site to gather information?
25 A; My recollection is that I was directed to go but I
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57 1 can't recall for sure whether I was made responsible, you know - -
2- vaguely --
3 0 Who else was directed to go?
4 A I don't know.
5 0 who directed you to go?
! 6 A That's not what I testified. I testified that I l 7 couldn't recall. The best I can recall, I was assigned this j 8 responsibility. I can't recall whether I was specifically 9 directed to go or if I made the decision to go on my own.-
I 10 0 Okay. Mr. Moore, I'm citing.and we can have it read 11 back. I asked you who these individuals including yourself was i
j u directed to go to the TMI site, if any. And your answer was, 13 "My recollection is that I was directed to go." Now, is that 14 your recollection that you were directed to go?
15 A To the best of my recollection, that's what it was.
16 You know, I'm not 100 percent positive.
17 Q To the best of your recollection,.that's all'we can 18 ask for. We understand it's a long time afterwards. Who B directed you to_go?
! 20 A That's what I'can't -- I can't recall being 21 specifically directed so I don't know who it was.
12 Oc It was obviously someone superior to yourself, is
! m that correct?
l 24 A If I was directed --
l 25 Q -Was it Mr.-Arnold?
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58 1 A I don't know.
2 Q How about Mr. Keaton or Mr. Croneberger?
3 A I honestly don't know.
4 0 It would have been one of those three individuals, 5 is that fair to say?
6 A It would have been somebody superior to me in that 7 organization if I was directed, but I can't --
8 Q I'm trying to get the people that -- could it have 9 been Mr. Arnold?
10 A It could have been Mr. Arnold.
i e
11 Q Mr. Croneberger?
tz A It could have been.
13 Q Mr. Keaton?
14 A correct. It could have been Mr. Wilson also.
15 Q Anybody else?
16 A That's all I can think of.
17 Q Do you know of anyone~else sent or directed to go to.
i 18 TMI?
19 A Liks I said, I can't recall whether these people were --
20 the notes would infer they were assigned responsibilities.
21 Whether they were specifically directed.to go or not, I can't 22 recall. !
23 MR. BLAKE: Ms. Bernabei, it's the.same question, St it's been asked and answered before and we're really wasting
~
25 valuable time and we're on a tight schedule.
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A 4 CQ l MS. BERNABEI: I'm trying to jog his memory. If his 2 memory was a little bit better we wouldn't take this time.
3 BY MS. BERNABEI:
4 Q Now, Mr. Moore, Mr. Keaton has testified that it was 5 decided in a meeting in Mr. Arnold's office that Mr. Broughton 6 and Lentz would go to the site, that that was decided at the 7 meeting. Do you remember anything of that sorc?
8 A No.
9 Q Do you have any information that that testimony's 10 incorrect?
! 11 A No.
12 MR. BLAKE: Do you_have a copy of the testimony?
13 MS. BERNABEI: Yes, I can show'it to Mr. Moore.
l 11 MR. BLAKE: I want.it.
15 BY MS. BERNABEI:
16 Q Okay, what did you do after this 10:05 a.m. meeting?
17 A Well, all I can recall after subsequent to that is 18 heading for.Three Mile Island.
19 Q Did you have discussions after'this 10:05 meeting l 20 with anyone?
l l 21 A I may have, I don't recall.
! 22 Q Did_you have any discussions -- you can't remember l 23 any more meetings, is that correct?
l St A That's correct, I don't recall-any beyond this.
1 25 Q How long was this meeting,_the 10:05 meeting? U 4tl6ER e LORIA REPORn964 SERylCE. INC 1000 MARKET ST MSG. PA 17101 HOG. 234 2109 PA 1400 222 SLR$ -
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1 A Here again, I really don't know.
2 Q. But your memory-is that immediately after the meeting 3 ended you went to'Three Mile Island?
l 4 A The,first thing I remember subsequent to the meeting 5- is going to Three Mile Island, t
6 O How long a period'after the meeting did you go to 7 Three Mile Island?
8 A I don't recall the specific hour that I left.
9 Q Was it an hour, two hours?
10 A EIt must have been within an hour or one or two 11 hours.
u O And if you can remember, what time did you leave D Parsippany?
14 A I don't recall.
l i
15 0 Would it have been noon, 1:007 I'm just trying to 16 get an approximate time frame.
17 A. It must have been --'I can't recall what time I got .
18 to Three Mile Island. I'm trying to work backwards from that.
I
.19 It takes about three' hours to drive up there so it had to have L
l l
20 been at least three hours before I arrived.
l 21 Q You arrived before 5 p.m., is that fair to say?
j 22 A. Yes, j 23 Q Maybe around 4-or so?
l 24 A In the backLof my mind itLwould seem to me it was-25 more like 2:00 or something like'that.
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61 1 Q That you arrived at the island?
4 2 A Yes, you know, I can't swear to it but that's in the 3 back of my mind, somewhere in that time frame.
4 Q So that would have necessitated you leaving around 5 11 a.m. or something of that sort?
-6 A Yes.
7 0 Is that right?
8 A' If I arrived at 2, that would have necessitated that.
9 Q We're just talking about an approximate time frame.
4 10 A Okay.
11 Q Now, you drove there, is that correct?
U A Yes.
13 O And did anyone go with you?
14 A I was alone.
15 Q Did you consider taking anyone with you or going with 16 anyone?
17 A I don't recall.
18 Q Now, there were others-who traveled from Parsippany 19 to the island, were there not?
20 A Yes. ;
21 O Who were they? l I
22 A The ones I can recall being there that evening were 23 Gary Broughton, Rich Lentz -- the others I-can't'be positive- i St which ones they were. )
%5 1) Was Mr. Lehman there?
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62 1- A I don't recall him being there.
2 MR, SLAKE: Objection, asked and answered. The
's 3 witness' prior testimony was that he doesn't recall Mr. Lehman 4 being there on August 28th.
5 BY MS. BERNABEI:
6 Q You're certain you went alone, is that correct?
7 A I don't remember anybody else being with me.
8 Q Do.you know whether or not Mr. Lehman went?
9 A I don't know. I can't recall him being out there.
10 .The only way of judging would be if I remembered him being 11 there that evening and I don't remember.
E Q .Okay. Now, did Mr. Broughton and Mr. Lentz, did they 13 travel down there together?
14 A I have no knowledge of that.
15 Q W' hat time did they arrive?
16 A I don't recall.
17 Q Were they there when you got there?
18 A I believe I was the first to arrive from Parsippany 19 - is-my recollection.
20 Q What did you do after.you arrived?
21 A Well, the first thing I tried to go onto the island 22 and it was blockaded so I went up to'the information center.
23 O Going back for a moment to others that may have N gone from Parsippany. Mr. Broughton has testified again'in the 25 B and W litigation that he believed'that someone else went with
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63 1 him, perhaps it was George Lehman. You have no memory of that?
2 A No.
3 MR. BLAKE: Do you have a copy of Mr. Broughton's l- .I testimony?
5 MS. BARNEBEI: Yes, I do.
6 MR. BLAKE: Can the witness see it?
7 BY MS. BERNABEI:
8 Q Well, would that refresh your recollection?
9 A It might, I sure don't recall --
10 MS. BERNABEI: Okay, let me show you for the record 11 the portion of Mr. Broughton's deposition and the GPU v.
U B and W ligitations specifically page 303. I would like you to 13 read starting at page 9 continuing through line 15.
l 14 MR. BLAKE: I believe it's line 9 through 15.
1 L
15 MS. BERNABEI: Lines 9 through 15, excuse me.
16 A Well, he says he doesn't know how the others got J
i 17 there so --
18 -BY MS. BERNABEI:
19 Q Well, my question to you is do you remember --
l 30 A Ch,.through 15.
21 O Yes.
22 MR. BLAKE: Now wait a minute,_you represented that-
! 23 it was Mr. Broughton's testimony that Mr. Lehman went with St Mr. --
t l 25 MS. BERNABEI: That he may have.
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64 1 MR. BLAKE: Well, let me read into the record his 2 statement at lines 9 through 15 --
3 MS. BERNABEI: Mr. Blake, could I see that for a 4 second?
5 MR. BLAKE: QUESTION: Who else from GPU from 6 Parsippany was going down to the island beside you and Mr.
7 Lentz --
8 MS. BERNABEI: May I see that for a moment?
9 MR. BLAKE: You may as soon as I complete reading.
10 ANSWER: I recall that Jim Moore went to Three Mile 11 Island that day and I believe another person who worked with n him went. I think that is was George Lehman. I don't recall 13 any'others who_went but there may have been others.
14 QUESTION: Did you all go together?
15 ANSWER: Mr. Lentz and I went in one car and I'm not 16 sure how the others went to Three Mile-Island.
17 NR. BLAKE: Can you substantiate your -- in a 18 -portion of that statement whic.h is an indication by Mr.
B Broughton that Mr. Lehman rode with Mr. Moore to Three Mile 20 Island?
21 MS. BERNABEI: I think you misunderstood my 22 question. My question was --
23 MR. BLAKE: Can we stop and have the question read 24 back, please, and-the representation by-this counsel of what 25 the testimony is?. !
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. 65 1 MS. BERNABEI: My representation and my question to 2 him and I don't think we need to have that if you're concerned 3 about time --
/
4 MR. BLAKE: I'd take the two minutes to have it read 5 back.
6 MS. BERNABEI: Mr. Blake, if you want to do that in 7 your deposition, fine.
8 BY MS. BERNABEI:
9 Q My question to you, Mr. Moore, and perhaps it was 10 misunderstood, was I believe another person who worked with him 11 went, I think it was George Lehman. My question to you is did u Mr. Lehman go, to your knowledge?
13 A I don't recall him being there. He may have gone, 14 I don't recall him being there.
15 Q Does this refresh your recollection as to whether or 16 not he went?.
17 A No, it doesn't.
B Q Let me ask you this, did Mr. Lehman in-fact work with B you during this period of time? Not speaking just of March 2Ett 20 but during that period of time.
21 A Before or after March 28th?
Z1 Q Before.
23 A Before March 28th? Let's see, my recollection is that a he worked with- Gary Capadonno. I l
25 Q Did he work with you?
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-1 A What do you mean with me, did he report to me or --
2 0 Did he work with you?
3 A We all worked -- it's an organization, we worked 4 together. I'm not sure I understand exactly what you mean.
5; O Did you ever work with Mr. Lehman, that is work on-6 any projects together or --
7 A As an organization we all interfaced with one another 8 and we worked with one another, yes, in that respect. In other 9 words, did we -- I want to understand the context of with.
10 Yes, we did' interface with George Lehman prior to and subsequent 11 to March 28th.
E! O Okay, and you can't remember whether or not he did
- 13 go to the island?
14 A I can't --
15 MR. BLAKE: Objection, asked and answered.
16 BY MS. BERNABEI:
17 Q. Can you, Mr. Moore?
E A No, I don't 19 - Q No, okay. Now, to your knowledge when did -- I think 20 you said you did know that Mr. Broughton and Mr. Lentz went to 21- the island?
22 A I can recall them being there that evening, that's 23 correct.
1 24 0- Okay, when did they. arrive, if you remember? -i 25 A I don't remember.
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67 1 MR..BLAKE: Objection, the same question was asked 2_ and answered.
3 BY MS. BERNABEI:
-4 Q Sometime after you arrived, is that fair to say, I 5 think that's what you said before?
6 A My recollection I was the first one.
7 MR. BLAKE: Obj ection. The witness has already 8 testified that he thinks he was the first one there, the group 9 from Parsippany.
10 MS. BERNABEI: And I was asking him the time, Mr.
- 11 Blake. I'm trying to jog his memory as to when the others n arrived. It's a perfectly appropriate question.
13 MR. BLAKE: I want to observe that it's now 11:30 14 and the time'for the next deposition and the state of the 15 questions and answers and the inquj~y which has been made in 16 the_ time available for Mr. Moore. Ms. Bernabei, I want to ask
, 17 you how much longer you expect?
E MS. BERNABEI: I would expect to continue the 19 deposition until it's completed.
20 MR. BLAKE: And what is your estimate of length of 21 time?
22 MS. BERNABEI: I assume the rest of this morning. .
23 What I would suggest, and we don't need to do that on the a record --
25 MR. BLAKE: Another half-hour?
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68 1 MS. BERNABEI: No, what I would suggest is that we 2 perhaps reschedule Mr. Porter.
3 MR. BLAKE: I don't know whether that's possible or 4 what his availability is.
5 MS. ..BERNABEI: Can we go off the record.
6 (Discussion was held off the record.)
7 (Recess.)
8_ MS. BERNABEI: You said_you were representing Mr.
9 Porter's position as well as GPU's?
10 MR. BLAKE: Right. We had a break. Mr. Porter 11 and counsel that represent Mr. Porter are here for his 11:30 m deposition. I've asked them whether or not he could come at a 4
13 later time because Mr. Moore's-deposition is not complete. At 14 some inconvenience they are prepared to have him come tomorrow 15 morning at 9:30 which was the Flint spot and we've agreed that 16 he will be here tomorrow morning at 9:30 and we'll continue 17 now with Mr. Moore's deposition.
B MS. BERNABEI: Thank you.
m BY MS. BERNABE1:
2D Q Mr. Moore, what did you do after you' arrived at the 21 TMI site?
22 A As I indicated I went up to the observation center s and at some point in time after my arrival I called back to
~g Parsippany and let them know I was there.
25 0 And who did you speak to when you went to the
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69 1 observation center?
2 A ~I really don't recall who it was. I don't recall 3 who I communicated with there.
4 Q Was it Mr. Herbein?
5 A I don't recall.
6 Q Was Mr. Herbein there when you arrived?
7 A He was there sometime during the day but I don't 8 recall-who was there at the time I arrived.
9 0 If you remember, Mr.-Herbein was there-when you 10 arrived?
11 A I don't remember if he was there or not.
n Q Would you have said that Mr. Herbein was the highest 3 ranking official of the onsite people'that was there at the 14 observation during the time you were there?
15 MR. BLAKE: During what-time are you referring to?
16 BY MS. BERNABEI:
17 Q Any time you were there on March 28th.
1 m A On March 28th?
m O I'm not talking about the service company people, I'm 20 just talking about the people --
21 A My recollection he was the senior person there.
Z! Q The senior person, okay. And you don't remember !
23 whether or not you saw him there at the time you arrived?
21 A That's correct.
25 Q Now, when was the first-time you talked to Mr. Herbein
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1 on that' day? -
I 2 A I don't recall talking to him.
3- -Q You didn't talk to Mr. Herbein at any time on 4- March 28th? ,
r 5 A I may have, I don't recall.
6 Q Did you talk to him at any time while you were at the 7 . observation center?
8 MR. BLAKE: On March 28th?
9 MS. BERNABEI: On March 28th.
10 MR. BLAKE: His testimony is he doesn't recall talkinc 1
i 11 to Mr. Herbein at all on the 28th. That's the third time
.. Ei you've askedithe same question.
, 13 MS. BERNABEI: He was in several different locations.
14 BY MS. BERNABEI:
15 Q Do you remember talking'to him at the time you were 16 in-the observation center?
17 A No, I don't -- I have no recollection of having B talked to him.
s- Q You did see him that day, did you not?
20 A I did see him, yes.
- 21 .Q And you saw him in the observation center?
22 A That's my recollection.
m Q And you can't remember whether you talked _to him at 24 that time?
25 .MR.:BLAKE: . Objection.
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'71 1 -A- No.
2 BY MS. BERNABEI:
i 3 Q Do you remember if you talked to anybody else in 4 the observation center other than people from the service 5 company?
i 6 A Are you talking about immediately after I arrived i 7, or --
8 Q Any time.
9 A Any time through midnight of March 28th?
10 Q Right.
11 A I talked to Gary Broughton, I talked to George Kunder, n Bubba Marshall and there vere other people there but I can't 13 recall, I can't put a face on them.
14 Q Now, did you talk to Gary Broughton in person?
- 15 A Yes.
16 Q Face to face?-
17 A Yes.
B Q And how-about Mr. Kunder?
19 A Yes.
20 Q Face to face? .
21 . 'A .Yes..
l 22 .O In.the observation center?
23 A Yes. When you say face to face you mean we being 24 the only individuals or --
25 0 No, what I mean is that_you were in the same room ,
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I together.
2 A Yes.
3 0 ; It wasn't by radio or telephone or some other --
4 A No.
5 Q And Mr. Mar'shall the same?
f r -
6 A Yes.
7 0 How about Mr. Lentz, did you speak to him?
8 A I was there continually on past midnight so the time 9 frame is fuzzy so sometime between my arrival and the time I i
10 departed the observation center I talked to Mr.- Lentz. l 1
I 11 'O Now, when did you leave the observation center?
m A Somewhere -- the best I can recall, somewhere around l
13 7:00.
t .
14 Q The next morning?
15 A The next morning.
}
16 O Okay, continuing on through 7 a.m. the next morning, 17 did you speak to anyone else in the observation center?
, m A There were a lot of people around I spoke to but
(
{- a like;I say I can't put a name on them.
20 .
.Q And you can't remember Mr. Herbein?
21 /A I can remember him being there but I can't recall 22 having a conversation with him.
23 Q To your knowledge was Mr. Herbein present in any of-M your conversations with any of the other individuals, Mr.
25
' Broughtoh, Mr. Kunder, Mr. Marshall or Mr. Lentz, whenever it 1 s
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1 73 1 occurred?
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o >
2 A I don't recall that he was.
3 0 When you reported back that you had arrived at the 4 site, to whom-did yo,u speak to at Parsippany? l
-5 'A I don't recall.. e It would have been to some superior, is that correct?
6 Q t I
7 A-I can't, recall Nho it wa,s.
8 Q I mean did'you call your secretary?
I 9 MR. BLAKE: Objection,-he can't remember who it was l
. 1 1
Ili he spoke with back at Parsippany. You can keep asking the 11 questions and we can keep spending time on the deposition the E same way --
13 BY MS. BERNABEI:
14 Q Did you speak to Mr. Arnold?
15 A I don't' remember who I spoke with.
16 'MR. BLAKE: You are badgering the witness when 17 you continue to ask him the same questions over and over..
B BY MS. BERNABEI:
- 1 l B Q Mr. Moore, am I badgering you?.
l
! 20 A I just don't remember.
l ,
21 -Q. 'I'm just th'ing y toLprobe your memory, I'm not trying 22 to badger you. '
) 23' A. If I rem'embered, I'd tell you, but I honestly don't I
.t.
24 -remember. 'l ,
8
. 25 ~ Q Okay, so you'got to.the site and'you reported back to
/ -'
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74 1 Parsippany. I guess my question was a little vague. Did you 2~
speak to someone on the administrative staff or your secretary 3 AM: ---
4 A That's what I said --
5- MR. BLAKE: Objection.
6 A I don't remember who I spoke with.
7 BY MS. BERNABEI:
8 Q Did you receive any information from Parsippany in 9 _that initial phone call?
A 10 To the best of my recollection was to stand by.
11 Q Stand by, okay. Now, at the time you arrived were u you pretty clear on what you were supposed to do?
U A 'Up until the time I arrived I was. I mean when I 14
.got to the gate I couldn't get through so I couldn't do what 15 I had come~up there to do.
16 0 Okay. So you got~to the gate, this is before getting 17 to the observation center, is that correct?
E A Right, I went to the gate to go on the island'and B it was closed.
20 Q Did you at.some time gain entry?
21 A On the 28th?
22 Q Right.-
- 23 A No.
24 Q But you were trying to actually get to the control 25 room,Lis that correct?.
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75 l I
l 1 A Well, I was trying to get into the plant, I don't 3
- 2. know if it was --
3 Q Well, into the unit 2?
4 A Right.
5 Q And you were barred entry, is that right?
6 A' Yes.
7 Q Now, what did you do? The guards at the gate said 8 you can't go to unit 2, is that correct?
9 A Can't get on the island.
10 0 Can't get on.the island. What did you do then?
11 _A Went to the observation center.
E MR. BLAKE: His prior testimony is that he went to 13 the observation center.
14 MS. BERNABEI: Mr. Blake, I'd appreciate it if you 15 didn't interrupt the question.
16 MR. BLAKE: That's the man's testimony, you don't 17 have to go over and over it again.
B- BY MS. BERNABEI:
B Q You went to the observation center?
2D A Yes.
21 'O You drove over there?
22 A Right.
23 Q And you were still alone at-this point, is that correct?
24 A .That's my recollection, I was alone.
25 Q Now, did you at any time after being barred from
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76 1 going to unit 2 seek by any other means to get to unit 2?
2 A No.
3 1Q Did you ask people at the observation center .is there 4 any way I can get over there?
5 A No, it was obvious that the island was closed.
6 Q Did you speak to Mr. Herbein about this?
7 A I don't recall speaking to him.
8 Q Did you speak to anybody in Parsippany about your 9 desire to get to the_ island?
10 A All I can recall the conversation I reported I was 11 there and I was asked to stand by.
u Q Did you tell them at that time I can't get to unit 2, 13 I'm here'at the observation center?
14 A I told them I was at the observation center.
15 Q Did you tell them, "I can't get to unit 2, what 16 -should I do?"
17 A I don't recall'the details of the conversation.
2 O Okay, but they told you in any case to stand by B where you are?
20 A Right.
21- Q Now, I. assume at least part of the task or 22- responsibility you understood'you had in your mind required l
23 you to go to the island at least when you started out?
24 A When I started out, yes.
25 Q And I assume.that when you were barred entry to the
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l 77 1 island and were at the observation center you weren't sure 2 what you were~ going to do, it was a little unclear?-
3 A That's right.
4 Q Now, what did you do at that point? When you were 5 -told to stand by, what did you do?
6 A Stood by.
7 Q .Did you receive any further directions?
8 A On the 28th, no. No, not on the 28th.
9 0 You received no further direction from Parsippany?
10 A No.
11 Q Did you receive any further direction from anywhere?
j u A Not that I recall.
D Q So you were standing by basically until 7 a.m. the 14 next morning?
15 A Yes.
16 Q So you were standing by. Now, what did you under-17 stand you were to be doing while you were standing by?
E A I had no directions so I was.just trying to learn B as much as I could.
20 0 And how did you do that?
21 A Well, at some. point in time people started coming 22 off the island so when they were reporting what the conditions 23 of the plant were I sat in on the discussions.
24 O~ And t..ese were people coming off shift or coming out? l j
l 25 A I don't know if they were on shift or what but they j I
i 1
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78 1 were people that had been on the island and were coming of f.
2 0- 'Can you remember any of those individuals?
3 A Well, I remember George Kunder.
4 Q That was around 6:00, wasn't it?
5 A Right, 6 p.m. That's correct, 6.
6 Q Was there anyone you remember before the 6:00?
- 7. A I remember a discussion with somebody prior to that;
- 8 here again, I.can't put a name or face so I can't envision 9 the person I was talking to.
10 Q What was the person's position?
11' A Somebody that had been on the island but I can' t E recall who it was.
D Q Ik) you remember, was it an operator, technician,-
- 14 GPU personnel?
15 A It was GPU personnel, right.
16 Q And this wasn't Mr.. Marshall?
17 A That was not Mr. Marshall.
M Q Now, your best memory is you got there around 2,;is B that correct?
50 A Somewhere around -- 2 is:something that just sticks 21 - in my mind, but whether that was the exact time I can't be 22 sure.
50 Q Now, the discussion with the individual, the GPU 24 -person, prior to 6, what was the substance or nature of that 25 discussion?
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- 1 A Well, that's reflected in_my notes. It was about 2 5-p.m. I'm not sure if it was one individual or who it was.
3 Q Okay, it appeared at the time to be someone who 4 knew what was going on in the plant, is that correct?
5 A Knew some aspects of what was going on.
6 Q Let me ask you this, what were you doing between the 7 time you arrived around 2 to 5 p.m.?
4 8 A Well, let's see, they were trying to getisome more 9 telephones in so I got some tools out'of my car. The 10 telephone people were-looking for some tools to open up some 11 manhole covers. That's the only thing I can recall between u 2:00, 13 Q That took you three hours to do?
14 A Well, like I said, that's one-of the things that 15 was going on. I stood in line for a good long time to call 16 back to Parsippany.
17 Q Was this before your reporting in call or was this 2 after?
B A No, that was the reporting in call.
2D Q How long did you stand in line?
21 A A long time but I can't --
22 O Half an hour, 20 minutes?
23 A Somewhere in the area of half an hour or something 24 like that.
25 Q. Now, after you called in what did you do? Is'this
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when the telephone line --
2 A They were trying to put in telephones, they were looking for tools; I had some'in my car. The rest of it I'm 3
4 sure there were other things.I was doing but I can't recall 5 what they were.
6 Q At the time you arrived.was there one telephone line 7 to Parsippany?
8 A 'I don't know how many there were.
9 0 You said you had to stand in line.
10 A Well, there wa:s a pay phone out by the curb.
11 Q Do you know if there were any phone lines open.
tz between the observation center and Parsippany?
13 A I don't know. The telephones inside were all in use.
14 I don't know what they were connected to.
15 0 You used the pay phone, you didn't.go into the 16
' observation center to see if you could call.from the observatio n f
17 center?
m A Like I say, they were all in use so I went out to --
s Q How many were in use?
20 A I don't know how many there were.
21 Q Two, three, four?
22 A I don't know.
23 Q A few?
a A I don't know,Lthere might have been only one, I' don't 25 know. Whatever there was they were in use.
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. . _ _ . _m. _ . _ _ _ - _
81 1 Q Okay, so you went out and used the pay phone and 2 stood in line for half an hour. After they told you to stand 3 by, what did you do? You said you started to gather as much 4 information as you could from where you were, is that 5 substantially correct?
6 A That's correct.
7 Q And that would take us to about 2:30 or so?
8 MR. BLAKE: We've continued now for'almost two hours 9 on a series-of questions about meetings or who were there, I 10 have yet to hear the first inquiry into the subject matter 11 which is at interest in the proceeding.
U MS. BERNABEI: I can represent.that Mr. Moore 13 apparently was sent to the Three Mile Island site to gather 14 information. It appears it was for the Parsippany of fice and 15 it would appear from individual's testimony outside this 16 restart proceeding was the purpose of informing Mr. Arnold.
17 And unfortunately he doesn't appear to remember too much so B we've had to go through a lot of other people's testimony to
~
, B jog his memory. It appears that --
20 MR. BLAKE: I think that's all interesting but I 21 just don't understand what it has to do with the proceedings, j 22 ' particularly since as you've identified the areas of interest l
to.him was the generator RC pumps and RC safeties quench tank.
~
23 24 MS. BERNABEI: You didn't allow me to finish, Mr.
I Zi Blake. . In addition, Mr. Arnold and Mr. Dhckamp had conversation s '
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82 1 in the afternoon or eveningaof March 28th at which time one 2 .w ould assume that they-spoke about what was going on at Three 3 . Mile Island. Therefore, I think it's important what this man 4 who apparently was a connection from the site to Mr. Arnold 5 what his position was and what he was doing at the' island.
6 That's why we have taken some pains to develop that under rather 7 difficult conditions.
8 BY MS. BERNABEI:
9 Q Do you remember anything else you did, Mr. Moore, 10 after you --
j 11 A Between the arrival and 5, no I don't.
E Q Did you speak during that time to anyone in the 13 control room?
14 A- No.
15 O What means of communication were set up between 16 yourself -- not between yourself -- between the observation 17 and the control . room and unit 2?
E A -I have the vague recollections of; radio contact but B there was an awful lot of communication with people --
20 radiation monitoring people too by radios, so I --
21 Q Radio contact?
22 A Radio contact. There was a lot of radio contact' 23 from the observation center; whether that was with.the --
24 my memory it seems to me some.of that was with the control room .
25 Q How about telephones, were there. telephones set up?
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83 1 A I don't know.
2 Q There's been testimony that there has been something 3 called voice communication. Was there anything with the 4 control room or unit 2 of that sort, intercom or whatever?
5 A Like I say, all I saw was radios in use and I saw at 6 least one telephone in use but beyond that, that's all the 7 communication I saw.
8 Q Okay. Now, during this period from 2 to 5, from the 9 time of your arrival till about 5:00, what information did you 10 have about what was going on in the unit 2 control room, that 11 is what was going on with the reactor?
E A I don't recall any. I'm sure I talked to people 13 around there but most of them were very actively involved in 14 trying to rectify the situation so I didn't try to engage them 15 in conversation.
16 Q Well, you were there to gather information, is 17 that right?
E A Well, I was originally sent out there to gather B information. Once I arrived I called back and I was told to 20 stand by so what I was doing was strictly on my own at that 21 point in time.
22 Q Did you have any understanding of what.was happening 23 in unit 2 to the reactor during the period 2 to 57 24 A I did not have a good appreciation for it.
25 Q Did you have any appreciation?
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84 1 A What does that mean?.
2 Q Did you have any knowledge about what was going on 3 in unit 2 during the accident this 2 to'5 period; let's say 4 2:30 to 5 after you made the phone call?
5 A You mean what was transpiring actually --
6 Q That's right.
7 A Real. time? No, I did not on a real time basis have 8 knovledge of what was going on.
9 O Let me phrase it a little bit differently..
- 10 Regardless of whether you knew simultaneously what was occurring, 11 'did you have any knowledge during that period of anything that u occurred between 2:30 and 5 in unit 2?
13 A I gradually assimilated information over, you know, 14
-from the time I arrived, you know, but as to when-I gained 15 specific types of knowledge, I don't recall.
J 16 O And the information you assimilated, what was that?
17 A Like I say, I don't recall what point in time I s assimilated. It was a very confusing situation and arriving s fresh on the s~cene I did not have a full appreciation of what-20 was going on. I didn't.have a clear picture in my mind what 21 was going on.
22 O Did you ever learn in the afternoon, let's-start 23 at any time prior to the 5 p.m. notes and I'll'ask you the 24 question for any time after,,that there had been a pressure mi spike?
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. 85 1 A No, I had no knowledge of that.
2 Q Did you learn that at any time on the 28th?
3 A No.
4 Q Did you learn that at any time in the early morning 5 prior to your leaving on the 29th?
6 A No.
7 Q Did you ever learn that a pressure indicator had 8 indicated an increase of pressure?
9 A On the 28th, 29th, no. Well, I'd say on the 29th 10 I'm not -- it depends if we're~ talking about the morning of 11 the 29th -- the morning of the 29th, no.
E! O Did you ever learn that the containment sprays had D been actuated?
14 A I don't recall.
15 Q So you may have learned and that would have been-16 sometime on the 28th?
17 A It would have been the 28th or the morning of the B 29th.
B Q So you may have learned about the containment 3D sprays, you can't remember?
21 A I can't remember.
22 Q Your training taught you at that time, did it not, 23 that those would be actuated only by an engineering safeguard 24 ' signal, is that correct?
25 A The sprays, right.
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c 86 1 Q And'did you know at that time that two out of three 2 _ independent sensors of pressure were required to activate 3 those sprays plus an ES signal?
t t
4 A I'm not sure if I -- I don't recall today what's !
i 5 required but I suspect I did at that time, I don't know. I
~
6 Q So if you learned about it you would have had that 7 background knowledge at that time, is that correct? ,
8 A If I had learned about it, right.
l 9 Q Okay. How about the fact-that an explosion had 10 occurred in the containment,'did you have any knowledge on i
I 11 March 28th through the early portion of March 29th?
U A No. !
l 13 Q How about tut hydrogen had been generated in the i 14 containment and reactor building?
15 A No.
16 Q Again during this time period from 2:00 on March 28th 17 through the early morning of March 29th that there.was concern.
2 -on site about hydrogen or a noncondensable gas possibly B causing -- in the containment possibly causing an explosion?
20 A No. .
21 Q Nothing.like that? >
I l 22 A No.
l
- 23 Q Did you have any knowledge or information during.that l i
24 period of.t'ime about a concern that activating certain 25 equipment in.or near'the~ reactor building could cause an
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87 1 explosion, that is a spark? '
2 A No.
3 Q Did you have any outstanding direction, outstanding 4 meeting effective instruction not to activate equipment?
5 A No.
6 Q What information did you have during this period of 7 time about the incore temperatures?
8 A Well, my notes I believe reflect this first five 9 P.m. conversation that incore temperatures readings exceeded 10 2500 degrees Fahrenheit?
11 Q Now, other than that did you have any other infor-l c mation?
l, 13 A I didn't even recall that until I read the notes.
14 Q Any other information now during this whole period 15 of time about incore temperature readings?
16 A No, I don't recall any. I may have but I don't-( 17 recall.
l M Q Did you know that temperatures, and I'm talking now m about March 28th, did you know or had your training instructed 20 you that temperatures greater than 2200 degrees indicated 21 essentially that hydrogen had been produced?
22 A No, I did not.
23 Q You did not know that?
i 24 A No.
25 0 Your prior training had not taught you that at that
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l 2 A No, I was not trained as an operator, as a core 3 designer, I was --
4' Q Did you have any information that at 2200 degrees 5 the reactor would be operating outside operating and 6 emergency procedures?
7 A I was not aware of this 2200 degree --
l 8 0 Did you know at the time on March 28th that 2200 9 degrees indicated that. basically indicated, that a cerconi and 10 steam reaction would occur?
11 A No, I did not.
1 u O Okay, now, how did'it come about that you spoke to 13 the individual who gave you the information recorded in your 14 5 p.m. notes?
! 15 A They came off the island, whoever it was, this 5 p.m.
16 and I sat in on their I call it debriefing. As I recall, it 17 wasn't a one on one. There was a group of us there and-this a individual was relating what they knew.
l m O Who else was there?
20 A I don't recall. I can't remember this 5 p.m.
l 21 conversation.
22 O Was Mr. Herbein there?
l L 23 A He may have been, I don't know.
l 24 Q Was anyone else from service corporation, Mr.
25 Broughton, fir. Lentz there, Mr. Lehman?
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89 1 A I don't recall if they had arrived at that time or 2 not.
3 0 Okay, so they may not have arrived?
4 A I don't even know if Mr. Lehman arrived that day.
5 but --
6 Q At all, right. But at the'other GPU Service 7 Corporation?
8 A I don't recall if they had arrived at that time or
( 9 not.-
10 0 So you don't know if they were at this meeting?
11 A That's correct.
U Q And Mr. Herbein may have been there, you don't li remember?
14 A It wasn't a meeting.
15 O It was a discussion?
16 A This individual was talking -- relating what they 17 knew. My recollection it was in the back room of the l
18 observation center where everything was happening so whoever
- B was around would have been in the room.
20 0 Was Mr. Herbein at some' portion in time he was in l
21 the observation center in that room?
22 A That's where he would have been -- that's where I l
23 would have seen him.
l 24 O He did spend part of March 28th in this back room i
25 : where things were happening?
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90 1 A 'That's my recollection, that he was and as I recall 2 I did see him back there.-
3 O And when you're saying this back room, was this 4 basically where the. radio communication'was going on?
5 A Right.
6 0 So the back room was where radio communication 7 with the unit 2 control room was taking place?
8 A Thore was radio communication with somebody there and
~
9 I believe I can remember hearing stuff over the radio from the 10 control room.
11 0 were you familiar with Mr. Herbein at any time making E! radio communication?
L3 A I don't recall specifically.
14 Q But you do remember him in this room where there was-15 also at certain points radio communication going on presumably 16 with unit 27 17 A There was communication with unit 2 and my .
M recollection is that some of it was by radio.
W Q And you remember Mr. Herbein in this same room, that':s 3D what I'm asking?
21 A Yes. .
M Q And is it fair to say that this was the central room 23 in the observation center where --
24 A This is where everything was happening.
25 Q This is where everything was happening, okay. Now,
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91 l 1 1 during the time you were at the observation center was this l
i-2 where you were positioned or stationed most of the time? Do
'3 you understand what I mean, is this where.you were staying, 4 sitting?
5 A I can recall early hours and later evening on into 6 the night that's where I was for the most part.
7 0 okay, so it's probably fair from let's say 5:00 on 8 this was your primary post?
l 9 A That's basically where I spent most of my time there.
10 0 And I assume you could hear any radio communication 11 going on? The individuals in that room could hear radio Ut communication?
13 A Well, there was a lot going on. If you went over 14 and you could go over and listen but it wasn't just one 15 communication,.it was communications with radiation people, 16 monitors and all kinds of things going on.
17 0 What I'm saying is anybody that was in that room B could have overheard radio communication that was going on if B they chose to listen?
20 A Yes.
21 Q Okay, now, this individual from the island comes into !
7 Zt the~ observation center, is that right, and he's debriefed?
A 23 That was my recollection. I can't recall who it was, l l
24 it was somebody that was talking.
25 Q Did you have a sense of how long that individual had i
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92 1 been at the island prior to 5 p.m.?
2 A I don't recall, no. I may have at the time but I 3 don't recall now.
4 Q Did you have a sense that the individual had been 5 there for a. specific purpose to gather information or the 6 individual had been working in unit 12?
7 A My recollection was somebody had been there involvei 8 but I can't recall what their responsibilities had been.
9 0 You said a debriefing. Who was conducting the 10 debriefing?
11 A I said it sort of in quotes, they were presenting n what they were doing. I don't recall if it was anybody-
- 13 questioning, it was more of an individual relating what they 14 had observed.
15 Q How many people were listening to the individual?
16 A I don't recall. Like I say, I can't -- I vaguely 17 recall this taking place but-I can't recall who was there or 2 how many. Like I say, it was a room full.of peoplei how many B of them were actually involved in listening to this I can't 20 recall.
21 Q Now a room full of people, how many are in the room 22 'whether or not they're listening to this person?
23 A I don't know --lots.
24 Q Thirty, forty?
25 A I don't recall at this point in time.
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93 I
1 Q 'I'm just trying to get a sense from you. Hov big is 2 the room first of all, this back room?
3 A I don't even recall that. I remember it was i
4 . crowded, that's all. I'd guess somewhere in the range of 5 20 people but that's a pure guess on'my part.
l 6 Q And at least as far as your memory takes you, how 7 many people were listening to this person, this man.that came 8 from the --
9 A Like I say, I don't remember how many there were.
10 Q Half that, the whole room?
11 A No, I don't think it was the whole roon.
U Q It wasn't a captive audience in other words?
l l
13 A Most of the people in there were actively involved l
14 in trying to handle the situation so everybody wouldn't have 15 quit their job to listen, they had real time things to handle.
I 16 0 Okay. So probably less than half these people were 17 actually listening to this individual?
i
! E A Less than half of what?
l B Q Twenty people?
l
- 20 A Well, you asked me for a' guess of how many were in l
t 21 'there.
- 22 O No, I'm-just getting a sense.
I 23 MR. BLAKE: This is certainly terribly improper that 24 you ask him outright guesses --
l 25 MS. BERNABEI: I'm trying to get his best memory. I !
1
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94 1 understand it was a while ago.
2 A .Like I say, I've got no memory of how many were
! 3 listening.
[ 4 BY MS. BERNABEI:
5 Q There was somebody else other than.just yourself?
I 6 A There was more than myself but how many there were, l 7 I don't --
8 O Three, four people?
l l 9 MR. BLAKE: Objection.
i l
t 10 A I don't know.
l 11' BY MS. BERNABEI:
l 12 O You don't know, okay. Less than the whole room, so 13' we know it's more than one and less than twenty, is that fair?
l 14 A It probably wasn't more than twenty people, it was 15 probably less than twenty people.
l 16 Q And you do not remember whether any other GPU Service 17 Company people were listening?
l 2 A That's correct, I don't remember if they were there B at that time or not; 20 0 .Okay, and it's probably fair to say that you would 21 have remembered something like that in a sense?
E A Not necessarily. I don't know if I would remember l 23 them being there or not.
24 O Now, your memory is that Mr. Broughton and Mr. Lentz '
25 arrived later in the day than you did?
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95 1 A Yes.
2 Q' And substantially later in the sense of three or so 3 hours perhaps?
4 A I don't recall.
5 'O Now, was there any reason that you preceded them, 6 that you came from Parsippany at an earlier time than the two 7 of them?
8 A I guess I started earlier. I don't know any other --
9 I have no reason to believe. I just left and headed on out.
10 0 Well, did it depend on the nature of your assignment?
11 A I just left,.you know. What they had to do, I have
! E no idea what they did between the time that they left and the 13 time they arrived.
14 Q Now, did someone ask this individual any questions 15 where there's a group of people listening in the back room of 16 the observation that asked this person coming off the island 17 questions?
E A I don't recall specific questions being asked.
B Q No, that wasn't my question. You said there were a 20 group of people, you don't know if it was -- you know it was 21 at least two and less than twenty listening to this person 22 who came off the island,'whoever it was, is that right?
23 A I said there was a group of people listening. i 24 0 What I'm asking you, did anybody in that group ask 25 this individual questions in this debriefing?
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96 1 A Like I say, I can't recall questions being asked, 2 that's not to say.there weren't. It's reasonable that people 3 would have asked questions but I can't. recall.
l 4 0 Okay, so it's reasonable that people would ask 9
5 questions. In other words, this man just didn't come out and l 6 gather together an audience and start talking to you all?
7 There were some people in the group that wanted to know 8 specific information, is that fair to say?
9 A Well, I think everybody there was trying to get a 10 sense of what was going on.
11 O It's reasonable to think there was some questions u asked?
13 A Yes.
14 Q Did you ask any questions?
15 A I don't recall having asked any.
16 0 .Now, reviewing your notes specifically the two pages
- 17 of notes that begin at.5 p.m.
L
- B A Yes.
B Q Now, the information that appears in these, were 20 these responses to questions or what do these represent as you 21 understand them?
Z! A My recollection is this is an attempt on my part to 23 summarize what the individual was relating, whether.it was 24 :just extemporaneous or in response to questions, I don't recall .
25 0 And what was the individual relating; what did he
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97 1 purport to be. telling the group.of people?-
i 2 A The conditions that he had observed over some period 3 of time while he was on the island.
. 4 O Okay, if you could review your notes, those two
! 5 pages, what period of time was he talking about?
6 A Well, the initial part appears to have started within 7 an hour af ter the trip.
8 0 You said that was prior to 5 a.m. or was that even 9 -earlier?
( 10 A Well, the trip was at 4 a.m., so --
11 0 I'm sorry you said prior to 4 a.m.?
l u A No, not prior to 4 a.m., it was within -- it looks 13 like it started -- there's some information that appears 14 to be from the time frame of within the first hour after --
l 15 approximately an hour after -- the trip at 4 a.m. So it would l
16 appear to start with events that occurred within.the time
- 17 frame of'S a.m.
L j 18 Q And what is the ending period on.that?
! 19 A I don't see anything that really ties down the ending 20 period. .I guess the fact that it occured at 5 p.m. would 1
21 indicate that the events here were things that' occurred between l
22 4 a.m. and 5 p.m.
i 23 Q So it might have been up to about 5 p.m.?
24 A Well, my' notes indicate -- it was in the time frame 25 of 5 p.m. that I took the notes so --
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i-99 r .
1 Q I'm asking you from your review of these two pages
? of notes whether it appears this individuals information 3 started sometime after 4 p.m. and continued on through the 4 time he came to the observation center at 5 p.m.? In other 5 words, this is the whole day, essentially the whole day up to 6 5 p.m.?
7 A I don't see anything else I can tie down the time 8
other than the fact that I took the notes-at 5.
! 9 O Pretty much I'm trying to get your sense of what 10 this individual was telling you.- He was telling you basically i
11 his knowledge of the conditions of the reactor during the E entire or the major part of the time he was at the island?
l 13 A Like I say, I can't recall who it was or how long 14 they had been at the island but they were relating conditions j 15 at the plant that, appeared to have spanned the time frame 16 between 4 to 5 a.m. and sometime in the afternoon of the 28th, 17 I can't find anything here that would give me a specific hour M that it had been stopped.
19 Q- That's okay, but sometime into the af ternoon of that 30 day?
( 21 A yes, right.
Z1 Q Now, did you have information that this man that was 23 giving you information was giving you accurate information? i 1
M A Well, I don't think he was lying to me, if that's
'M what you mean.
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99 1 !Q No, I guess what I'm asking you 'is did you get the sen ce 2 that he had been in a position where he could give you
's information that was accurate or reliable information?
4 A He had been on the -- whoever it was had been on the 5 island, observed certain things and they were relating what 6 they were. I had no basis for disbelieving the credibility l
l 7 of the individual.
l 8 O No, I'm not talking about credibility. What I'm i
9 asking you is did you have any reason as you listened to this j 10 individual to discount or not to have confidence in the 11 accuracy or reliability in the information he was giving you?
l 12 ' 'A I had no reason to, i
i 13 Q Now, at the time this individual was speaking to you, 14 did you know how he had gathered the information he was l 15 presenting to you?
16 A You mean by direct observation or second-hand? No, l
17 I have no recollection of that.
18 O But it's fair to say that he appeared to have access
! B to the information that.he presented?
20 A He had some information, right.
Now,'how long did his presentation or his discussion 21 Q-22 with you take?
Zi A 'Like I say, I can't -- I can vaguely recall it M taking place but I can't recall the duration of it.
25 MR. BLAKE: Ms. Baranbei, can I ask just how long you
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j <
100 1 expect this to be and ask whether or not the witness wants 2 coffee?
3 MS. BERNABEI: I'm not sure, about 1:30 maybe. Mr.
4 Blake, can we keep going?
5 MR. BLAKE: Yes.
6 BY MS. BERNABEI:
7 O Okay, Mr. Moore, referring now to about two-thirds 8
down the page, incore thermocouples read 2500 degrees Fahrenheit .
9 A Yes.
19 0 Do you remember that's what this individual related 11 to you, is that correct?
u A That's what my notes reflect so that would have been --
13 Q Okay, at that timo did you have any indication how l l
14 those roadings were mado, what kind of equipment had made those 15 readings?
l t 16 A I don't recall him having had any knowledge of that.
17 O So you can't remember how the individual told you 18 how thouc ratings were made at that time? !
l 19 A No, i
- 3) Q, Woro there any questions or discussion about how those 21 readings had been made?
22 A Not that I can recall.
zi i .0 Is it fair to say that those notes repronant a 28 comploto not of anything important that individual may have 25 ' told you ot anything you considorod important? You were trying e ,
I
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ini I to be complete and comprehensive? -
2 A I was trying to capture the thoughts that seemed 3 to come across.
4 O 3
And you were trying to be as complete as possible?
5 In other words, anything that you felt was important you would 6 have quoted, is that fair to say?
7 A That's my normal habit.
t 8 Q Sure, okay, and this was in your mind the first persor 9 that had really come to you since the time you were at the 10 observation center with information that you considered
.1 l
11 significant enough to write down?
l D A I think this is the first person that I talked to 13 that had been in the control room.
14 Q Is it fair to say that you were fairly careful in 15 l
taking these notes in the sense that this was important 16 information to you? ,
17 A What do you mean by careful?.
B
.) i Q - Well, you wouldn't omit things that you considered 19 significant?
20 A I don't believe I would have, no.
21 Q And these are accurate notes of what you heard, is 1
22 that fair to say, to the best of your knowledge? '
23 A To the best of'my knowledge these- would be St accurate notes.
25- .O I guess what I'm trying to capture is your sense of ,
' '. ^l
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l 102 1 the time. This was the first person with firsthand information 2 that had been on the island during the time you were there, is 3 that right?
4 A Right. As I recall this was the first individual 5 that I overheard talking about it or heard talking about it.
6 O Okay, when you were told about the incore thermal-
- 7. couples reading greater than 2500 degrees Fahrenheit, was there 8 'any discussion in the group about those temperatures that you 9 can remember?
10 A I don't recall any.
11 Q None at all?
12 A No.
13 0 Was there any discussion about those temperatures 14 after the individual had related this series of conditions?
15 A I don't recall any other discussions regarding the 16 thermalcouples..
17 0 I think it's your prior testimony you did not know B on March 28th that those temperatures indicated the
- 19. steam reaction would have taken place, that is that the -- or 2() -the operator was. operating-outside of its emergency and 21 operating procedures?
22 A. I~did not know that 2200 degrees was the number.
23 'O Now, moving to the second page of the notes on 5 p.m.,
Si it says,'" Dick Bensel electrical engineer", is that correct?
25 'A That's correct.
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103 1 Q Why'did you-write those in your notes?
2 A I don't know. He may have been the individual that 3 was talking. -He may have been one of the individuals in the 4 group, I don't know.
f5 Q Okay, so he may have in fact been this individual who 6 was relating this information to you?
7 A He may have been, right.
8 O~ Do you have any memory as to how long this took?
9 A No.
10 Q Half an hour, 45 minutes?
11 A It was just a --
, El Q No. Did you have any discussions about this 13 information with anyone else after it was given to you?
14 A I can recall, you know, sometime at some point in the 15 evening after -- I recall discussions with Gary Broughton about 16 the whole, you know, other things that were going on so it 17 would have included things of th'is' nature.
18 Q _Okay, so you would have related to him at that time 19 what you had learned?
20 A Yes.
21 .Q Did you have any discussions with.Parsippany?
22 A. No, I was not -- just had the one' communication with 23 Parsippany. I did not have any subsequent that I can recall.
24 Q: From the' observation center?
25 A Fromfthe observation center,right._
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104 I Q Did you have any: conversations -- I'm just going to 2 ask you about some people because it might jog your memory --
3 with Mr. Arnold?
4 A I don't recall having any.
5 0 You can't recall? -You know for certain you had no 6 conversations with Mr. Arnold?
7 MR. BLAKE: Objection. He said he had no conversatior s 8 with Parsippany.
9 MS. BERNABEI: He said he can't recall and I'm asking 10 if you're certain about that.
11 BY MS. BERNABEI:
U Q Are you certain about that, Mr. Moore?
13 A Yes. I can't be certain that I didn't have any but 14 I can't recall.
15 Q You can't recall but you are not certain, is that 16 fair to say?
17 A That's --
18 Q. You're not certain, you may have discussed it.with 19 ' Mr.. Arnold but'you can't recall at this time?
20 A I can't recall any communications with Parsippany.
21 Q. "But you may-have had them but'you don't remember, is
. 22 that right?
23 A -Yeah, it's possible.. There's a' lot of. things that I'- -
)
.M 'Q~ .You're not certain, that's-all'I want to establish, 25 you're not-certain,-is thattright?
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105 1 A That's right.
2 Q How about Mr. Wallace, can you recall any conver-3 sations with Mr. Wallace?
4 A No.
5 Q Are you certain you had no conversations with Mr.
6 Wallace?
7 A No.
8 Q How about Mr. Keaton?
9 A Like I say, I have no recollection of talking to 10 any individuals in Parsippany.
11 Q Are you certain you didn't talk to Mr. Keaton?
E A I' don't understand what you're --
13 O I'm asking you, Mr. Moore, there's a difference 14 between certainty and not recollecting.
15 A I have no recollection of being on the telephone 16 other than the one time so --
17 Q I'm not talking about the telephone. Did you B communicate whether by radio, in person ~, by. telephone, I don't a care how you did it,oor-through someone else. Perhaps you gave 20 someone.a message and the message.got through? Did you 21 communicate in any way with Mr.-Keaton about this information, 22 any of the information whether or not the notes, the specific 23 information, the information in general? ,
St A Like I say, I have no~ recollection of it.
25 . O But you're not certain, is that right? You're'not
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106 1 certain that'you did not speak or otherwise commur,1cate_with 2 Mr. Keaton about this information?
3 A_ If I: communicated with him and I forgot about it so 4 I guess --
5 0 You're not certain, is that true?
6 A I guess that's right.
7 Q You're not certain, okay. Now, Mr. Broughton you 8 said you did speak to?
9 A That's correct.
10 Q How about Mr. Croneberger?
11 A No recollection of talking to him.
m Q Are you certain that you did not speak.to him or 13
_otherwise communicate with him about the information in these 14 notes?
15 A Your definition of certain, I can't absolutely say 16 that I didn't, no.
17 Q And Mr. Capadonno, did you' speak to him or otherwise 18 . communicate with him?
19 A No recollection of talking to him.
30 0 Are-you certain about him?
21 A No.
22 Q How about Mr. Lentz, did you speak'or otherwise 23 communicate to Mr. Lentz about the information in these notes?
m .A I spoke and communicated with him because-he was 25 there in,the observation center. As to whether I communicated
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107 1 the contents, I'm not sure..
2 Q How about Mr. Lehman?
3 A' I don't recall whether he came that day or not.
4 Q That wasn't my question. The question was did you at 5 any time March 28th, March 29th, or any time thereafter, .
6 communicate the information in your notes?-
7 A Not to my recollection.
8 Q And are you certain about Mr. Lehman?
9 A No.
10 Q You do have a memory however that you spoke to Mr.
11 Broughton?
d A Right.
13 Q Now, what time was-that?
14 ' A I don't recall. 'It would have been after he arrived-15 there and I don't recall what time he arrived.
16 Q Okay, so it would-be shortlyfafter he arrived, a few 17 minutes? In other words, was it in the nature of briefing him,-
B the nature of-telling him what you had been doing?
B A It would have been in that nature.:
2D Q .Did you show him the notes?
21 A I' don't recall.
22 Q Now, to your knowledge you would have transmitted 23 the information in the notes, isLthat.right?
M A It would'be reasonable that I would have handed him 25 the. notes to look at.
1 1
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108 7
1 Q Now, do you know if he communicated the information 2 in the notes to anyone else after you transmitted that 3 information to him?
4 A I'm-not aware of his communicating with anybody.
5 O Do you know for a fact that he did not?
6 A' No, I don't know for a fact that he didn't.
7 Q. Do you'know of any calls or communications he made to 8 Parsippany after the time he arrived and after the time he 9 spoke to you?
10 ;A I can't recall observing him making or being aware of 11 any.
E! O I'm not asking you on that date, do you know now?
13 ' A Do I know now?
14 O Do you know now if he made any communications whether 15 by. telephone,.radi,o or any other means with Parsippany?
16 A I'm not aware of'any communications.:
You're not_ aware of-any?
~
17 Q 18 A No.
19 Q You know that would cover :-- you. don' t know of any .
20 -communications he'had with Parsippany on the.28th.or the 29th?
21 A- On. the 29th, what time frame cui the 29th? .
52 Q Anytime on:the_29th?
23 A :The only time I can recall'being with him -- I recall-
-being with him on the 28th,_that evening. I'm not aware of any 24 25 communications that he had. 4
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109 1 Q I'm talking ~about up to the present time. I'm not 2 saying simultaneously, I'm saying do you now know of any 3 communications he had at any time in those two days with 4 Parsippany?
5 A No.
6 Q Is it fair to expect that he would have reported 7 into Parsippany at some time as you yourself did?
8 A I don't know.
9 MR. BLAKE:L Objection. I just don't know how 10 appropriate it is to ask this gentleman whether or not it's 11 fair to expect that Mr. Broughton may have reported into u Parsippany at some time, is that your question?
13 MS. BERNABEI:- That's the question. He was in the 14 same --
15 MR. BLAKE: I have an objection to it.
16 MS. BERNABEI: I can represent he was in the same 17 group of people that was given assignments and'sent by 18 Parsippany to the site.- It seems to me he understood how this B group of people were working.
20 BY MS. BERNABEI:
21 Q Let me ask you, would you expect Mr. Broughton to 22 report into Parsippany as you yourself did at some time after 23 he arrived at the TMI site?'
St A' I don't --
25- Q- You wouldn' t expect --
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110 1 A I don't even know if -- he may have communicated, I 2 have no idea what he did. I really don't know.
3 Q I'm'asking you a little different question. You 4 wererin a meeting with Mr. Broughton?
5 A Are you asking my opinion or what I know?
6 Q I'm asking your opinion.
7 A Are we here for opinions or what I know?
8 0 You were in this group of people,.okay. We have a 9 representation from you that Mr. Broughton gave you some 10 information in the 9 to 10:00 frame, okay, you have a note here.
11 A Well, there's one note there, right.-
E Q One note, okay. And then we have some information that you were at-a 10 a.m. meeting and at'that meeting or in
~
13 14 that time frame you were'at least giveri an assignment. You 15 were given certain responsibilities and you wereigiven a 16 direction sometime in that time frame to come to the site.
17 What I'm asking you is given what you knew and given people's .
18 assignments including Mr..Broughton's responsibilities that B are listed at the 10 a.m. meeting, would you expect that he 20 ' would arrive at the site and'at some point report back to 21 Parsippany from what-you understood of his responsibilities?
22- A I was.trying to recall what -- I can recall being.
23 askedito call in_when I got there.- Whether that applied to M. everybody or .f i it was the first individual to arrive that was 25 supposed to call back or what, I_ don't know. I can recall the
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111 1 direction when I arrived there to call back, other than that 2 I can't --
3 Q What I'm asking you is giving your understanding of 4 Mr. Broughton's responsibilities whatever that was, do you 5 think he reported back to Parsippany?. Would that be your 6 understanding.of what he was supposed to do?
7 A I really don't know.
8 O You have no idea?
9 A I don't know.
10 Q Is that your answer?
11 A I don't know what his directions were.
E Q What did you do after the 5:00 discussion?
13 A Well, the next thing -- my next set of notes -- what 14 did I do, I don't have a recollection.
15 Q How long was there between this individual-relating 16 this information to you and-the 6:00 meeting?
17 A I don't recall the duration.
18 Q Half an hour?
B A I have no. recollection.
20 Q Did you do anything to your knowledge between this 21 individual's talking to you about these factors and the 6:00 22 meeting? Did you. talk'to Mr. Broughton?
23 A I don't recall when he arrived.
24 Q Well, do you know that he came with Mr. Lentz?
25 A No, I didn't-know that. You showed me testimony that
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112 1 he did, other than that I didn't.-
2 Q Assuming that he came with Mr. Lentz and there's also 3 testimony that Mr. Lentz did and I think Mr. Broughton as well 4~ received a briefing from Mr. Kunder, that would imply, would 5 it not, that they arrived sometime before Mr. Kunder gave his 6 briefing at 6 p.m.?
7 A -That would be reasonable, right.
8 Q ,Now, is it fair to say that if they in fact were at 9' the. observation center for Mr. Kunder's briefing at or sometime 10 prior to 6 p.m. that you may have spoken to Mr. Broughton about 11 the previous conversation _or discussion, the 5 p.m. one with c him, prior to 6 p.m.?
13 A I have no recollection, you-know, of the timing of 14 it.
15 Q But you said it was in the nature of a briefing, in 16 other words, shortly after he arrived you told him about it, 17 .is that right?
18 A I was working with him very closely from the time of B- his arrival, you know, we worked together.
20 Q So it would be fair to expect that you would show him
- 21. your notes or. talk to him about theLinformation contained in 22 the notes soon after he arrived?
m A Yes.
~m Q Now, what happened-at 6:00 to the best of your Zi- memory?
2
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113 1 A' That's-when George Kunder had apparently-just come off 2 the island and:I recall the conversation was,.you know, again
, 3 it was some group of people and he was presenting what his
, 4 _ understanding was of what had happened.
5 Q Was this also in the back room of the observation 6 center?
7 A That's what I recall.
8 Q Okay,_who else was present at that meeting?
9 A Here again,-I don't recall who was there.-
10 Q Do you remember if Mr. Broughton and Mr. Lentz were 11 there?
E. A I. don't recall if they were there by that time or not.
13 0 You have no reason to think though that any testimony 14 - that they have given that' they were was incorrect?
15 A It would be reasonable that they would have arrived 16- by then.
17 Q Okay. Now, how about Mr. Herbein, was he-there?
E A I don't recall.
m Q- You don't recall Mr. Herbein?
20 A I recall Mr..Herbein-but I don't recall if he was 21 there at that time or not.
22 Q Do you remember _when Mr.-Broughton, Mr. Lentz arrived --
l 23 . or stick to Mr. Broughton because you tio seem to remember you 24 worked'with him. Did they speak to Mr. Herbein?
25 A. _I don't recall.-
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e 114 1 Q Mr. Herbein was the highest ranking official then, is 2 that right?-
3 A Right.
4 MR. BLAKE: Objection, asked and answered.
5 BY MS. BERNABEI:
6 0 You don't remember whether or not they spoke to Mr.
7 Herbein when they arrived?
8 A I don't remember.
9 Q You don't remember? Do you know if Mr. Broughton 10 ever talked to Mr. Herbein?
11 A On the 28th?
E Q On the 28th, 13 A I don't recall them seeing them, I couldn't say that 14 they didn't.
15 0 When Mr. Kunder came off the island, what did he say-16 or do?
17 A Well, it's related' here in my notes which looking at 18 them would judge that they're a fairly complete set of summary 19 of what he related.
-m Q Now, how many people were in on this discussion or 21 conversation?
22 A I can't' recall.
23 Q~ For or five people?
24 A- Your guess is as good-as mine.
25 0 . Ten people?
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119 1 A I don't recall. There again, you know, there was a 2 lot of people in the room but how many were-actively listening 3 to the --
4 Q How many people were listening at all, 10 people, 5 20 people?
6 A I don't know.
7- 0 Was it about the same size group as the prior 5 p.m.?
8 A I told you I didn't know how many were in that, I don't
- 9 remember how many were in this.
10 0 Well, what I'm trying to get a sense is if people 11 came off the island was it a pretty set group of people that u were listening -- that were doing basically what you were doing?
13 A Most of the peopl'e that were there were actively 14 involved in responding to the event.
15 O' Okay, so we would assume that it would be perhaps 16
.somewhat less than half of these people, maybe around 10 or so 17 that were listening?
B A You're guessing, I don't-know.
B Q There was more than just you?
20 A 'There was more-than myself, right.
21 Q Were there more than two people listening?-
22 MR. BLAKE: Ms.'Bernabei, I just have to object.
2 If.you don't regard it as badgering, I certainly do.
31 LA I don't remember.
25 BY MS. BERNABEI-l
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116 3
1 Q Were there more than two or three people? I'm trying 2 to get a sense, Mr. Moore, of what was going on. I'm not 3 trying to badger you, I'm trying to jog your memory. Now, 4 you have testified in other proceedings that Mr. Broughton was 5 there, okay. What I'm trying to sense from you is do you 6 remember anybody else? Was it just the two of you?
7 A Like I say, I don't recall it being just myself and 8 George Kunder and I am fairly certain it was not just myself 9 but there were other. people present but just as to how many and 10 who, I have no recollection.
11 Q And how did it come that Mr. Kunder was explaining-u these conditions or these events to you? In other words, how 13 did you come to find Mr. Kunder?
14 A I was there and he came.
15 Q And did you know Mr. Kunder prior to March 28th?
16 A Yes.
17 O And you had.come in contact with him in your normal 18 course of business?
m A Yes.
20 Q Did he come specifically to see you?
21 A No.
m Q Why did he come to the observation center?
23 A I don't know'.
St 0- When he came there,~who did he speak to?
25 A I have no recollection of observing who he. talked to.
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m-117 1 Q What I'm asking, how did this discussion or 2 conversation get set up? He didn't come to see you, you said 3 specifically?
4 A No, he didn't come there to see me, no.
5 Q Did he come to see anybody else?
6 A I don't know.
7 O Well, who set up this discussion group?
8 A I don't know.
9 Q You don't know who Mr. Kunder came to speak to first?
10 A No, I don't know.
11 Q But it wasn't you? Whoever it was, it wasn't you?
E A I have no idea what motivated him to come there.
13 Q How did it come about that you began to listen to 14 Mr. Kunder or~ talk to Mr. Kunder?
15 A Like I say, I was trying to get tc' understand what 16 had transpired that day.
17 Q Did someone introduce you to Mr. Kunder; say, "Here's B George Kunder, talk.to him?"
E A I don't recall that being the case.
30 Q Was it in the nature of a briefing, at least for you?
21 A Well, in the sense that he was relating his 22 observations and I was taking advantage of that to try to. gain 23 understanding of what had transpired.
':M Q Did you understand that this had-been set up for 25 your benefit?
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118 1 A~ Not to my knowledge.
2 O Why was this briefing or this presentation set up?
3 A I don't know. You're making it sound very formal, 4 I don't know if it was that formal.
5 Q I'm just trying to find out why Mr. Kunder came at 6 6 p.m. to the observation center.
7 A I don't know why.
8 QI You have'no idea why he came?.
9 A No, I honestly don't.
10 Q At the time he came did you grab him off and say, hey, 11 I want to get some information from you?
E A .Not that I recall.
13 Q Well, how did it come about that you did hear a 14 certain presentation or briefing that he gave?
15 A It would be just supposition on my part how it came 16 about. He was there, he was' talking about.it so I sat and 17 ' listened to it.
18 Q And he recognized you and he came up and said I'd
- 19 .like to tell you what's going on?
20 A No, he didn't:say that.
21 Q And you didn't say thateto him, right?
22 A Not that I recall.
23 Q So it appears.that someone'else in this group set 11 up or arranged this discussion, doesn't it?
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119 1 talking, I don't --
2 Q So it may have just been spontaneously he came over?
~3 A It may have been that.
4 Q Do you know that Mr. Kunder returned to the island 5 after this briefing?
6 A Is that a question or a statement?
e 7 Q No, I'm asking you.
8 A Are you saying do-I know if he did or --
9 Q ;Do you realize that he did?
10 A You're saying that he did?
11 Q. .Yes.
E A Okay.
13 Q Now, I'm asking if you're aware of that?
14 A I-can't recall anything that would --
15 Q Are you aware that he went back with Mr. Lentz after 16 this briefing or presentation?
17 A I was aware that Mr. Lentz went to the island at some-M point in time.
19 Q. Were_you aware why Mr. Lentz.went to the island?
A A My recollection is that he went over to get some 21 of the data related to the transient.
22 O Okay, what are we talking about now. data? What-kinds 23 of things are we talking'about?
- :M A -Well, he did subsequently return to the information
~
25 --
center and he had a computer printout of about the first eight
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, 120 1 and a half minutes as I recall of the --
2 O Eight and a half minutes?
3 A Eight and a half minutes worth of -- I can't recall 4 what specific device that came off from.
5- Q Well, I guess my question to you is a little different 6_ is what kind of data did you understand he was going over to 7 get?
8 A It was --
9 Q It was generally data on the accident of the transient ,
10 is that fair to say?
11 A Right.
U Q Okay, and was he restricted with the time period?
13 'A I don't know.
14 Q So it could have been the whole day -- the whole day 15 up to that point?
16 A We would have liked to have gotten our hands on 17 ~ anything we could have gotten our hands on.
18 O Okay, that's what-I'm trying to get. So at least as 19 you understood it, you and he and Mr. Broughton were there to 20 'get as much information as you could? In other words,'you 21 weren't restricted about-the concern of the first eight minutes 22- or the first three hours or the --
23 A No, we were trying to understand what had happened 24 and what was happening.
25 Q Okay. Now, is it fair to say that Parsippany -- the
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-- _ . . . _ . ~ . . _ . . . . .. . ._ _ _._ _
p 121 r
t
- 1 individuals at Parsippany -- wanted information on what was ;
I 2.- happening? In other words,:you were..sent down there basically, E
p 3- yo'u know, on assignments for Parsippany?
'4
~
j .
A' 'Well, the whole situation when I arrived was. totally P
j- 5 different than that envisioned at the time I left.
i 61 Q- I understand, ~ but that's. not what I'm askirig you...
7 I'm asking you generally you.were on an assignment from' j' '8 Parsippany'to find out what's going on, what.had-gone on.and i 9 -what was-happening?
I 10 'A No, when I left.Parsippany my assignment was to find i
.o 11 out.what had happened to specific items of~ equipment.- When I .
l E arrived'the situation was significantly.different,than.we C
i 13 ' understood at the time I left and_I was told.to-stand-by. ~ So 14 - my assignmenti in essence was to stand by; at . that- point in time. -
.i
!- 15 ' Q_ Now, how was it significantly.different?
A
- 16 MR. BLAKE
- How was what significantly different?
4 l 17 ' MS.;BERNABEI: He said the situation was significantl) j 18 <different;when he arrived:-and I'm trying_to. sort of-get a
- i. 19 sense of.how.
- . - 2) MR.1BLAKE
- He's testified to that,-he:couldn't get. ,
21 ~on[theisland. '
j 22 A I couldn't get on the_ island. _
23 '. BY MS..BERNABEI:
! 24 Q~ No, no,'but that changed your~. idea'of your assignment. What
.- 25 I'm trying -to get at was -the -situation- with - the ' reactor different . ' ' - -
4
+
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122 1 .there were different events that had occurred?
. 2- A The accessibility of the information was inaccessible 3 to me, the thing I went down to do originally.
4 Q No, what I'm asking you is a different question.
J 5 You said you went down to find out about specific equipment, 6 right?
7 A Yes.
8 O And.you said that changed whenSu2got there. What I'm 9 asking you is you may have had the same assignment, it may.
10 have been that you couldn't do it but you had the same?
11 assignment. What I'm asking you is you seem to say that you E felt that you had a different assignment at that point.
13 A Well, when I called back.to Parsippany I was told to
. 14 stand by, so to me --
15 0 And that meant to you a different assignment, a 16 different quality of-assignment?
17 A That-was recognition on their part that I was unable B to do what I was originally dispatched to do and that stand by 19 _and we'll let you know what you should do next.
20 O' Did they ever let you know what you were to do next?
21 A Ultimately.
22 MR. BLAKE: Objection, asked and answered.
23 BY MS. BERNABEI:
2A -0 When?
25 A Ultimately the next day.
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( 123 b
1 Q So you had no direction as to what you were to do 2 until the next day?
3 A None that I can recall.
4 Q And stand by you interpreted it in saying don't 5 worry about that equipment you're supposed to find out about 6 but gather as much information as you can? I mean, that seems 7 to be what you're saying generally? That was the nature of 8 the change in your assignment that was occasioned by your not 9 being able to get onsite?
10 A Well, as I recall my directions were to stand by, 11 you know, I'm standing by. I wanted to find out as much as I E could so --
13 Q Why didn't you leave and go back to Parsippany?
14 A I was directed to stand by.
15 Q And stand by meant to you to collect as much infor-16 mation about what was going on?
17 A It neant to stay there until we give you further B direction.
19 Q Did it mean also to collect information?
20 MR. BLAKE: Objection. He has never stated that that' s 21 what his interpretation was.
22 MS. BERNABEI: Mr. Blake, are you directing him not 23 to answer the question?
M MR. BLAKE: Well, you can answer that for yourself, 25 have you heard those words?
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124 1 BY MS. BERNABEI:
2 Q Mr. Moore, did you understand the change in your 3 assignment that you were then not supposed to worry about 4 specific equipment but to worry about collecting information 5 about what was going on?
6 A I don't recall having been directed to do anything 7 other than stand by.
8 Q That's not what I'm asking you, I'm asking you a 9 different question. I'm saying did you understand in your 10 mind that your assignment had changed so that from that point 11 you were supposed -- it was your duty or responsibility or u however you want to put it, with or without specific direction, 13 to find out what was going on, that was the nature of your 14 assignment at that point?
15 A Like I say, I don't-recall having anybody assign me 16 responsibility to gathering any information. My only 17 recollection was that I was directed to stand by. I don't 18 recall any direction --
B Q Why were you. listening to these people? Why were
.m you gathering this information?
21 A Because I felt a-personal responsibility to become 22 knowledgeable on just what was going on.
Z3 Q Why? Did you feel that was a part of your-respon-24 sibility as standing by?
25 A Because as an individual. I felt that I had, you know,
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125 1 part of my job was to become knowledgeable about what was going 2 on and if you couldn't accomplish what you were sent for, I 3 felt that -- to see if I could understand what was going on.
'4 Q Did you understand after you got there and up to the 5 point of 5 p.m. that the situation or the accident was 6 significantly more severe than it had been previously 7 recognized?
8 A In the early parts of the -- in the early afternoon 9 .I did not have a -- I.could not' grasp the situation. I did not 2
10 have a good mental picture of what had transpired and what 11 the situation was.
U Q Now, how about the period now 2 to 5 p.m. when you 13 say you arrived at 2 to 5. Did you understand during that 14 period that the situation, that is the reactor was in a conditic n 15 such that the accident was more serious than had been 16 previously realized?
17 A I'm trying to recall what -- my recollection was that, 18 you know,,I came to appreciate that there was at least some B core damage during-that time frame. I-don't recall whether it 20 was prior to' leaving Parsippany.-- I think we had some indicatior 21 that there was activity and that' sort of stuff but I don't 22 think I had any appreciation for any core damage until sometime 23 .and I can't put a time frame on that as.when I' began to M become aware of it. All I can remember is that I did not have 25 a, good appreciation';of.what was going on or what had happened
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126 1 until sometime into the late evening.
2 Q Okay, is it fair to say when you're talking about 3 core damage that you did not appreciate --
you certainly 4 .didn't appreciate the core damage prior to 2:00,'is that. fair tc say 5 A Not to my recollection, I don't recall having any 6 knowledge about any core daraage prior to that.
7 Q -How about the period now 2 to 5 prior to your taking 8 these notes and being briefed by this individual? Did you get 9 a'ny appreciation of core damage in that period that you had 10 not previously recognized?
11 A I don't recall.
E Q How about at,5:00?
A
~
13 At 5:00 the notes would indicate that at this point 14 in time I was getting some indication of -- that 2500 degrees 15 was an abnormally high-temperature.
16 O Anything else in those notes that.would indicate that?
17 A I didn't have a full appreciation of where'the 2 activity was coming from but, you know, the. core damage was 19 really the high dome reading of 1000 R, core damage was sure a 20 possibility.
21 Q Okay, now you're reading from the-top of the second 22 page?-
23 A Well, the top of the first page at 5 p.m. on the 31 second line there's a dome reading of 1000 R.
25 MR. BLAKE: Can I.ask whether or.not you are going to
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127 1 link these up at some juncture to the subjects at issue in this 2 proceeding, that is, pressure spike, hydrogen, etc., in this 3 line of questions which are currently pursuant?
4 MS. BERNABEI: Core damage, yes.
5 MR. BLAKE: -You're going to link these questions up?
6 MS. BERNABEI: I think core damage is directly I
7 related. He has stated that at least one of the basis for his i 8 leaving there was core damage,which was not previously realized I
9 was incore temperatures --
l 10 A I said I began to appreciate --
11 BY MS. BERNABEI:
l E O You began to appreciate it, sure. Now, how about l
L 13 anything else other than the high dome reading?
l l 14 MR. BLAKE: While he's looking, can I ask you what 15 your estimate now is and when you will be complete?
16 MS. BERNABEI: Half an hour at the most.
i l 17 MR. BLAKE: I'm leaving at- 1:25, I have an appointment 18 at 1:30 and-since this has been going on now-hours well over 19 what it was scheduled for, I'm going to terminate at that point, 20 (Discussion was held off the record.)
l 21 BY MS.'BERNABEI:
22 Q Mr.. Moore, anything else in these notes?
23 A I don't'see anything else in my notes.
I 24 Q, Having been given the fact that there was more core i
25 damage in part. at least from the 'two . factors in those notes, dicl
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128 1 you feel any responsibility at that time to inform your 2 superiors of what you had found, what you had learned?
3 A I was aware that communications were going on between 4 people there and Parsippany.
5 Q You're talking about communications between the
, 6 observation center and Parsippany?
7 A Yes.
8 O And so'you assume that whatever you knew had already 9 been passed on, is that fair to say?
10 A That's correct.
- 11 0 So'you saw no particular necessity at that time to u you yourself inform Parsippany as~to what was going on?
13 A That's correct.-
14 0 Now what led you to an awareness or an assumption 15 that communic' a tions between the observation center and Parsippan y
16 had passed on this type of.information?
17 A I was aware that communications were going on. I B :was not aware necessarily of the content of it.
19 Q Who-were the communications going on to and from?
20 A I happened to have a list of telephone numbers for 21 some people in Parsippany and I was giving people telephone 22 numbers for.,some period of time. Who they were, I don't --
23 , Q ~Mr. Herbein?
St
'A He's not at Parsippany, he wasn't in Parsippany.
25 , O Okay, we'll start with the telephone numbers. Whose
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. s 129 x
I telephone numbers did you give out?
2 A Thats what'I say, I don't recall.,
3 0 _W ell, would it have be'en the people in 'this meeting, J 4- Mr. Keaton, Mr. Croneberger, thosepeoplethatwebebtillin ( \
5 Parsippany? '
6 A I don't recall. 'I can remember.getting the book out -
7 and looking for telephone numbers and I can remember getting .
, l 8 the book out'and giving people telephone numbers on more than 9 one occasion but I can't recall --.and in fact I think some of 10 them were home phone numbers in-addition to office numbers. ,
11 Q Okay. Now, what level are we talking'about? Would E2 these be' people that were of your level or your superiors?
13 A It would be my superiors or my superiors' counterparts 14 in some other --
15 Q Superiors' counterparts, would that.mean basical,1y 16 the superiors of the people that we.'.ve already Salked*about?
17 A .Yes, directly up_above Bob Arnold down to myself, B yeah, I would consider them my direct superiors. The other ones.
19 would be people off in:other departments-and that sort of -a 1 -
20 thing.
21 - .Q Who would those be, people'off in the.other >' s 22 departments?
- m. MR. BLAKE:. .Ms. Bernabei,f do you really_ regard-that-31 as an appropriate questirk e- thispoint,whoeverwerepebrs.
. 25 of his' boss'.in the r,P; .ce Company.in 1979?_ You have
. a: -
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130 4 1 better. ways of obtaining.that information and I think this
^~ ~2 ~ witness has --
3 MS-. BERNABEI: I'm trying to understand whct level 4 we're. talking about.
5 BY MS. BERNABEI:
6 0 'When you say superiors' counterparts?
7 A 'AsJI say, it's.the'same level as my bosses or --
8- Q But in other divisions of the GPU Service Company?
9 A Right.
10 Q' Did you have any knowledge of anyone trying to 11 communicate with Mr. Dieckamp?
D A No, I was not aware of any. ,
- 13 Q They didn't ask you for his-phone number?
14 A They might have, I don't remember.
15 0 So they: might have even asked you for Mr. Dieckamp's 16 phone number?
17 A Correct, they might-have. Like I say, I don't recall B who.it was.
B Q- Just so-I understand, and I don't want to burden 20 you with. useless questions,'but when you say your superior 21 conterparts and other--parts of the service company, you're -
22 _ talking'about sites outside of~the-nuclear, is that right?
23 A .' N o , I'was talking about -- I1was in engineering and-M the engineering ' from Don Croneberger there was this direct-25 reportinguline up:to Bob _ Arnold'and there were other departmento
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s 131 1 besides engineering that would be off in some of these other --
2 I: don't believe I would have had telephone numbers for anybody 3 outside of the nuclear -- well, it wasn't nuclear at that time - -
4 Q Can you remember any communication or any conver-5- sation about contacting Mr. Arnold?
6 A I have no direct recollection of anything.
7 O But you're not certain, it may have occurred, somebody 8 may have asked you?
9 A They may have. I might have very well given out 10 phone numbers for him.
11 Q How about Mr. Dis:kEmp'? You said you might have been a requested and you might have given out his phone number.
13 A I don't even know if I had his.
14 Q But it~might have been someone who asked you how to 15 get into communication?
- 16 A Yeah, it might have.
17 Q Anybody else, Mr. Capadonno?
m A I doubt that I.would have had his phone number.
19 Q Your sense was that some of the people in the 20 observation center were trying to.get in contact with-some of 21 the service company people at their_ homes, right?
f 22 A I did give out some home phone numbers.
23 O Do you know whose phone numbers those were?
24 A No, I don't..
25 0 Whose.home phone numbers did you have in the group _
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i 1 of-people we've been talking about?
2 A- I suspect I had all of them.
3 Q So you had all of_the phone numbers of your superiors 4 up to Bob Arnold?
5 A Like I say, I don't recall, but I had a goodly i' .6 number of-home phone numbers,
! 7 O Is it fair to say up to Bob Arnold?
8 A. Yeah, I had his phone number.
9 Q Now, this period when you were giving out phone 10 numbers or people were talking about getting in touch with the 11 service company people, I assume this extended into the L u evening-hours?
13 . A Right.
14 Q And do you know what time we're talking about, some-15 time-after 5 or 6 it's fair to say?
16 A I'm not sure when I gave out -- that whole time frame 17 just went on and on so it's'hard to put hours.
18 Q But at least we're. talking about some portion'of the o
a evenir.g , right after these people would have gone --
10 A At least some.of these calls were-after the15.to 6 21 time frame, that's true.
l l- 12 O Now, did you have a sense thattpeople in Parsippany.
l . -
23 whether or not you can identify particular' individuals were M involved in discussions about what:actionsLto take with the-25 ' reactor? ,
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1 A I have no knowledge whatsoever of what was happening 2 back there.
3 0 Now, you're familiar, are you not, with discussions j' 4 in the morning, morning perhaps early afternoon, in'Parsippany 5 about~ starting a reactor coolant pump?
'6 A There had been an attempt to start one but they .
7' couldn't get it started.
8 O My question-to you was there some concern or perhaps .
i
-9 sense that perhaps one should be started? Do you remember any 10 discussions about that?
I have no recollection of that.
I 11 A D 0 okay, but you're not certain?
P 13 A No.
1-1 Q Now, do you remember any' discussions and again this j 15 would probably be during the period when.you were in the '
16 observation center about Parsippany being concerned about the 17 high pressure injection?
18 MR. BLAKE: You're still planning to tie'this up, l 19 Ms. Bernabei, to the items that are-at' issue in this proceeding,
! 20 is that right, high pressure injection, whether or not it was l
21 on or off, whether or.not to start the' reactor coolant pump, l
22 these.are all tied up.to hydrogen generation pressure spike?
! 23 MS..BERNABEI: Yes.
21 MR. BLAKE: Okay,-well I'm-still waiting.
25 A I don't recall any particular discussion of that.
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17A 1 BY MS. BERNABEI:
2 Q Are you certain?
3 A There may have been a lot of discussions going on, I 4 don't recall that.
5 O' I guess what I gather from-your prior answers that 6' there was in some sense!Parsippany was being informed as to-what 7 was going on?
8 A While I was at Parsippany there were communications 9 between some individuals at Parsippany and some individuals at 10 Three Mile Island.
11 Q And in the afternoon as well and into the evening?-
12 .A- I have no knowledge whatsoever about that other 13 than the fact that the people were calling Parsippany personnel 14 and I was giving them telephone numbers.
15 0 And.isfit fair to say that your sense-was that you 16 didn't have to.tell Mr. Arnold-or-any of the other people in 17 Parsippany about what you had found out at 5 p.m. because 2 there were other people calling them up?.
!!F A My sense was that.these people that were calling them 20 'had a better-feeling of what was going on than I did.
21 Q. Now, you saidlyou did work with Mr. Broughton for thit ZF period of time.when he was in the observation center. Did~you 23 get the same sense from him that.he was passing that~informatiori 24 on to1Parsippany?
25 AL I don'.t recall.
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135
~1 Q Now,' do you remember any conversation about Mr.
2 Kunder's briefing?
3 A I can visualize portions, you know. I vaguely recall 4 talking to him but I don't recall.anything about the questions 5 and the answers.
6 Q Okay, now, as I asked you before, this is a' fairly 7 ' complete accurate recording of his comments and whatever 8 comments?
9 A There are somefplaces here where I stopped writing 10 in midsentence but other than that.
11 O And it's fair to say that your understanding then u and now that Mr. Kunder was in.a position where he wbuld 13 understand and have complete access as to what was going on 14 on the first day, the first day of the accident?
15 A I was aware that'he was in the control room.
I 16 MR. BLAKE: iMs. Bernabei, do you think you'll be 17 done in the next three minutes?~
M MS..BERNABEI: Probably --'maybe. -
B BY MS. BERNABEI:
20 Q Mr. Moore, what did you do after the briefing by Mr.
21 Kunder?
~
22 A Well, at'some point in time Rich Lentz came back with a the first eight and a half minutes of information and' spent l
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$ a portion analyzing that to try to figure out what had transpired 25 during the'first eight and a half minutes.
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136 1 Q Were you doing calculations and things of that sort?
2 A Right.
3' O And who was doing-it, yourself and Mr. Lentz, anybody 4 else?
S' A Myself and Gary Broughton -- there were other 6 individuals there but-I can't recall exactly who had arrived 7 by that time.
8 0 Other than the first eight and a half minutes, did 9 you talk about anything else that had occurred?
10 A- I'm-sure we talked about'a lot of other stuff.
11 Q I mean anything relating to the accident. Did you u talk about anything other than the first eight and a half 13 minutes?
14 A At the. time we were.trying to gain an understanding 15 of what had happened so I'm sure we talked about a lot of 16 other things.
17 0 You mean outside that eight and a half' minutes?
E A Right.
And did Mr. Lentz bring back with him any information
~
19 Q 3D about the. pressure spike that occurred at 1:50 p.m.?
21 A. Not that I'm aware of.
22 Q Any data, any copy, any photocopy of the pressure 23 recorder?
N A All- I recall is he just had information on the first.
J 25 eight and a half minutes.
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137 i
l' Q Did he say anything,that you can remember about the 2 pressure spike?
3 A Not that I recall. I had no awareness at all on the
- 4 28th or the early part of the'29th of anything about the 5 presssure spike.
6 Q What was your sense of why Mr. Lentz had gathered 7 'information or data on the first eight and a half minutes?
8 Why was it that that was the!only short period that he had 9 gathered data for?
10 A That's all that was apparently available to him at l
l 11 that point in time.
U -Q So he would have liked to get more but that was all 13 he could find?
l 14 A Well, that's all that was available and that's it.
l 15 Q Did he have any notes, anything of that sort?
16 A I don't know.
17 Q Now, you were aware at that point, were you not, that 18 they had changed the strategy that the reactor had been 19 repressurized or in the process of being repressurized?
20 A At some point in time I had a note that they had l
l l- 21 repressurized -- 1905 on the last page of notes.
l 22 Q And that was from Mr. Kunder? '
l
- 23 A I' don't know.
l 24 Q I'm sorry,.this is where?-
(
! 25 A This.is on the notes with George Kunder but.it was the'
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138 1 very last entry. There's a line drawn under the previous line 2 so I'm not sure what that reflects.
-3 0 ~ Yes but isn't this the point that they reached 2300 4 PSI?
5 A You're asking me? Wete talking about change of 6 strategy, isn't that what you're talking about?
7 Q That's exactly what-I'm. talking about. Now what I'm 8 'asking you is the 1905 that appears on the last page, it says 9 they had taken plant back up to 2300 PSI gone solid, is that 10 fair?
11 A Right.
U Q But doesn't that mean at 7:05 it was up to 2300 PSI?
13 A That's correct.
14 Q And at that point it had gone solid or was in the 15 process of going-solid?
16 A Right.
17 Q Now doesn't that indicate that the strategy may have B . changed,it had started sometime prior to'that?
19 A Like I say, I didn't have a' good understanding of 20 what was going on all throughout that day. But, you know, in 21 retrospect this would indicate a change in strategy looking 2 at it today.
23 0 Did you know at that time or do you know now when 24 that change of stratgey' was ef fected?
5 A -No, I have no knowledge of that.
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139 1 Q Do you know how it was done, by what method?
2 A By.what?
3 Q How it was repressurized, what was done to repres-4 surize it, whenever it occurred?
5 A They just stopped trying to repressurize it.
6 Q Did they draw a bubble in the pressurizer?
7 A Well, when they said they went solid there wouldn't 8 even be a bubble in the pressurizer, it would be solid, you 9 know, not even a bubble in the pressurizer.
10 Q Okay, but this-was at some point down the road when-11 'they had begun to repressurize it, is that fair to say?
E! A I don't know.
13 MR. BLAKE: How much longer,.Ms. Bernabei?
14 MS. BERNABEI: I have a few more questions.-
15 MR. BLAKE: I'm sorry, but as I indicated before 16 I've got to get going. - How many more questions do you have?
17 . MS. BERNABEI:- I would say at the most five minutes.
B PGl. BLAKE: Okay, well then we'll plan on being back 19 at a quarter to 3.
30 MS. BERNABEI: Okay.
21 (Recess.)
22 BY MS. BERNABEI:
23 O' Okay, Mr. Moore, I just;have a few more questions.
m You said that you had a communication'or discussion with a 25 Mr. Marshall, is that correct, Bubba' Marshall?
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140' 1 A I was present when he was. debriefing some of the 2 operators.
l 3 Q And what time was that?
4 A I believe it was somewhere in the neighborhood of 5 midnight, I believe. I can't really put an exact time.on it.
6 Q And.when you said Mr. Marshall was debriefing the
! 7 operators, at.the operation center, is that correct?
8 A Yes.
9 Q And these were operators essentially coming off'the I
10 island?
l 11 A I'm not sure if they were coming off or going on.
u O But certainly operators that were just going to the 13 ' island wouldn't have much information, would they? He was l 14 trying to get information about what was going on?
I 15 A Aboutwhat had gone on, right. The people that would 16 have been going on at midnight would be the people that had
- i. 17 been there the day before.
18 Q March 27th?
Yes.
~
19 A
- 20 Q Okay. So he was debriefing people that worked on 21 March 27th',and 26th about what had gone on?
22' A Well, specifically there was Gregg Foust and Ned 23 .Fredrick, the ones I recall. As I recall they were present at M. the onshift at the time.
I 25 0 .Anybody else you can remember?
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141 1 A That's the only ones I recall.
2 .Q And what was the nature of the information he was 3' eliciting?
- 4 A As I recall it was basically just what they had done 5 during -- you know, what happened and what the response had 6 been.
7 Q Starting with Mr. Foust, can you remember what he 8 said either in general or in spec'ific terms?
9 A- I can't attribute to either one of them exactly what 10 they said.
11 Q Can you generally state what you remember?
E A Well, they had gone -- they were just~ going through 13 the first part of the accident about the different things, 14 the scram and the different trips and all that and what they 15 had done in response to it but I can't recall the details.
16 Q Did they pretty much give a chronology of the first 17 day as you remember it?'
1 18 A A chronology to some part, I can't recall where it 19 ended.
20 0 Can you give me an approximation, was it the evening, 21 early afternoon, late afternoon?
22 A .I really don't know.
23 LQ Assuming for the moment that they were actually.
24 coming off work,'that is coming --
25 LA I don't know. It-wouldn't make sense to me that they
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142 1 were coming off, they would have been there for 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br />. They 2 .went on shift at 12:00 the night before so it wouldn't make l 3 sense they had been there for 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> and been coming off so 4 I would be hesitant to make that assumption.
5 Q Is it fair to say that whatever information they 6 were giving was up through the time they had lef t unit 2? I
- 7 mean they were giving you all the information they had 8 basically as far as their understanding that they were aware of 9 during their shift? Now, did they at any time speak about 10 a pressure pulse or a pressure spike?
l 11 A Not that I recall.
l u O How about initiation, actuation of containment spray?
13 A I don't recall if they did.
14 O Did they speak about the engineering safeguard signal 15 that had gone on at any time during-the time they were in
~
16 unit 27 l
17 A I can't specifically recall, you know. The makeup 18 pumps had started so I would guess,-you know,-the fact that B they did have 'high pressure injection initiated that requires 20 a safeguard signal to do that so I presumn.they would have 21 talked about that.
22 Q Do you know whether or not they talked.about the
. initiation or actuation of the containment sprays?
23
[
St- A I have no recollection at all about any' containment l
t 25 sprays.
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143 1 Q But you're not certain, is that fair to say? You 2 said earlier you may have received information about contain-3' ment sprays.
'4 A It may have been discussed but I can't recall any 5 discussion of it.
6 Q Let me just ask you about your awareness on March 28th ,
7 if containment sprays had been. discussed, I think it's your 8 testimony that you realized they could be initiated.or actuated 4
.9 only by an ES signal and.two or three pressure sensors, is that 10 . correct?
11 A. Or manually, i
U Q Or manually, right. Assuming it was not manual, if 13 you were informed about actuation of containment sprays, you 14 would have realized would'you,not'that there had been an 15 -increase of pressure up to 28 or 30 PSI, real increase in 16 pressure?
17 A I don't recall what the set point is to start it so 18 I don't know if I would have been aware of that pressure being
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m required or not.
20 Q Well, it would have been at least'above four or five, 21 is that fair to say?
12 A I don't remember what the set point was.
23 Q Some increase in pressure?
. 38 A' Yes, some increase in pressure. .I was aware'that '
25 there was some increase in pressure in containment on that' day.
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144 1 I was not aware what's referred to as the spike.
2 Q When you say increase in pressure what are you talking 3 about now? You're taking about that period of time generally?
4 MR. BLAKE: What period of time?
5 BY MS. BERNABEI:
6 0 2 p.m.
7 A As i recall if you've got the George Kunder notes 8 and'those others there as I recall, I think that his notes 9 reflected something to do about containment pressure.
10 0 Are we talking about Mr. Kunder's notes now?
11 A That's what I can't recall which one. It seems to me u that one or the other reflected -- the bottom of the second page 13 of the conversation of George Kunder.
14 Q And did you have an idea of what --oka y, that's 15 at 2.5 PSI, is that right?
16 A Well,"it says, " Containment pressure peaked at two 1
17 and a half PSI initially, went up to containment building M pressure of four PSI.
19 0 Do you know for what time period?
20 A No, I don't'.
21 Q. From the general chronology or the. general sequence 22 of events that is given here, can you give me an estimate of a the approximate time that's being talked about?
M A No, I couldn't.
4 25 O So it's fair to say Mr..Kunder in his remarks to you ,
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145 1- was not giving you a sequence of events or a chronology?
- 2 A To a degree but I couldn't say. absolutely that 3 everything in there is in sequential order.or chronological
'4 order.
l 5 Q So you did know then that there had been a pressure
,6 :hcrease to four PSI at some time on March 28th?
7- A .That's correct.
8 O Now, were you in your conversation or in this l 9 debriefing of.Mr. Foust and Mr. Fredrick, was there any l
l 10 mention or discussion about an explosion or-a chemical reaction, 11 anything of that sort?
U A No.
l 13 0 Was there any discussion of.any instruction not~to 14 activate equipment for fear of an explosion of noncondensable l 15 gas of any sort?
16 A I had no awareness on that day of anything having to 17 do with hydrogen.
l , M Q Cantyou remember anything else that Mr. Marshall said 19 or Mr. Fredrick or Mr. Foust?
, 10 MR.-BLAKE: I.have to object to that question.
21 A No, I don't.
l 22' BY MS. BERNABEI:
21 Q Nothing else?
l 24 A- No.
15' Q_ Did any of.those individuals speak of core damage or
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v 146
, I the extent of core damage that they perceived at that point?
2 A I don't recall those details of the conversation.
3 MR. BLAKE: I note, Ms. Bernabei, it's been well t
4 over now five minutes. Are you about done?
5 MS. BERNABEI: I have a very few questions.
6 MR. BLAKE: What would be your estimate of additional j 7 time?
8 MS. BERNABEI: Well, it would-probably take us about 9 another five minutes to talk about it and another five minutes l 10 to actually question Mr. Moore.
11 BY MS. BERNABEI:
u O Is it fair to say at the time you received this 13 briefing, this goes back to our conversation or your testimony 14 before about what you realized from-the 5:00 briefing,that i
15 you realized there had been serious core damage.
16 A All I said is there had been some core damage, I l
17 didn't say serious.
18 Q How would you characterize it, your appreciation at 19 that time?
l 20 A Just that-there had been some core damage. I'really l
21 didn't have any basis for judging how much.
22 Q More than you previously had believed, is that 23 correct?
24 A More than previous to what now?
l 25
- Q Previous to receiving that briefing at 5:007
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147 1 A I think what I testified before was that I gradually 2 assimilated this information and over some period of time I 3 gained the knowledge that probably there was some damage to 4 the core. Now, as far as what period of time I assimilated 5 that, I can't really attribute any period of time to that.
6 0 Well, we're talking about March 28th, right?
7 A Yes.
8 Q What I'm asking you is how you appreciated or 9 evaluated the core damage?
10 A You mean compared to what we know today?
11 O Yes, u A Compared.to what we know today, I did not appreciate 13 that there was anywhere nears the extent of core damage that we 14 know about today.
15 O But it was much worse than you had believed is 16 possible in the early morning hours?
17 A I didn't know what had happened earlier. It was a 18 gr'adual assimilation of understanding over a period of time.
19 0 If you had had to evaluate or state what degree or 20 what portion of the core had been damaged, how would you have 21 evaluated it at that point in time on March 28th?
22 A I have no basis for making that judgment. I didn't g3 have the knowledge of what had transpired and I was not an 24 expert in the area of core damage.
25 Q What I'm asking you is, I'm asking you for your
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r-148 1 personal opini'on with the background you have understanding 2 what it is.
3 .MR..BLAKE: Ms. Bernabei, I --
4 A I don't jump to-conclusions.
5 MR. BLAKE: I must object to a line of inquiry 6 following_this witness' testimony which says he's unaware of 7 hydrogen, unaware of the pressure spike, unaware of in my view.
8 items which are. involved in'the proceeding.
9 MS. BERNABEI: The thermalcouple temperatures are 10 involved in the proceeding and he said that he formed his 11 basis for his appreciation of the core damage from those U temperatures. So I think I'm entitled to ask him to clarify 13 what he-meant by core damage. That's what I'm attempting to do.
11 MR. BLAKE: Okay. So your question is what 15 appreciation did he have of core damage based on his --
16 MS. BERNABEI: Based on that and the other infor-17 mation that he had.
2 MR. BLAKE: -- upon learning that the temperature was 19 2500 degrees?
,2 MS. BERNABEI: Based on that and the other informatior i 21 available to him at that time.
22 MR. BLAKE: What other information available to him 23 at that time?
N MS. BERNABEI: He said the radiation readings and 25 he said --
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149 1 MR. BLAKE:. That business is not involved here, you 2' know that.
3 MS. BERNABEI: I do not have to separate my questions 4 to him what tua appreciated from one -factor alone. Those are 5 the factors I can question on.
6 BY MS. BERNABEI:.
7 O Mr. Moore, after the 5:00 briefing whether you 8 reached this opinion immediately after that or sometime after 9 that, what was your evaluation or sense of the degree of core 10 damage?
- l 11 A My sense at that point in time was that I did not l
l C appreciate there was any extensive core damage.
13 0 Would you characterize it as minor core damage, minori
! 14 2500 degrees and you believe was minor core damage, is.that i
L 15 what you're telling me?
l 16 A What 1 have told you is that I did not have an l 17 appreciation for how much it was. You're the one that's trying 18 - to ask me how much there was. I did not form an opinion at j B that point in time as to what the extent was. -
l l
SD Q Is it fair to say it was not minor?
21 A I did not form an opinion at that time.
22 Q You believed there was some core damage?
23 A I believed there was some core damage.
N Q And more than you had previously believed was l 25 possible?
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150 1 A Well, I guess this more than previously -- I think 2 what I testified is that --
3 Q Previous to 2:00 when you arrived at the site, 4 A Prior to that I guess I wasn't aware of any core 5 damage and there might have been some indications in the 6 morning and I'm trying to recall all of this.
7 Q The radiation readings you mentioned?
8 A Right. I say gradually over the day I assimilated 9 information.
10 0 What I'm asking you is after realizing that 2500 11 degree temepratures in the radiation readings which you pointed u out, what was your evaluation or opinion as to the extent of 13 core damage?
14 A I said I didn't form an exact opinion of how much 15 because I had no basis for --
16 Q Well, more than you previously believed prior to that 17 time?
B MR. BLAKE:- Please let the witness finish his answer.
19 MS. BERNABEI: Well, he wasn't answering the 20 question.
21 BY MS. BERNABEI:
22 Q Mr. Moore, I'm just asking you as compared to your 23 prior appreciation --
24 A Prior to 5:00?
25 0 Prior to 5:00.
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151 I
1 A Yeah, I'm sure that gaining whatever time it was that 2 I got the information on 2500, that that would have influenced 3 my opinion or.at least firmed up my opinion that there had been 4 at least some core damage.
5 Q Okay, fine. Did you collect any further.information,
! 6. and I guess I'm using this in'the broad. sense of the word 7' collect? -DM you gain any knowledge or information about the 8 condition of'the reactor after 12:00, after this debriefing 9 of Mr. Foust and Mr. Fredrick?
10 A' I don't recall any subsequent to that.
11 0 You mean nothing subsequent to 7 a.m.?
u A To 7 p.m.?
13 0 7 a.m., I'm sorry.
14 A The time we're talking --
15 MR. BLAKE: Is your question whether or not-he had 16 gained inquiry to appreciation of the accident ever after.7:00 l
17 a.m. on March 29th?
l 2 MS. BERNABEI: No.
B BY MS. BERNABEI:
20 Q My question to you is, you've discussed a briefing or 21 a debriefing of Mr. Foust and Mr. Fredrick around midnight, is 22 that correct?
l l 23 A Right.
24 O And that was conducted by Mr. Marshall?
25 -A Right.
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152 1 0 I'm asking you, did you collect or gain any other 2 information about the reactor from midnight until 7 a.m. when 3 you said that you left?
4 A I can't recall obtaining any additional -- I was 5 there, present, things were going on but I can't recall, you 6 know, nothing sticks in my mind.
7 Q Were you briefed by anyone else that you can remember 1 8 A Not that I recall.
9 Q Were you and Mr. -- were Mr. Broughton and Mr. Lentz 10 - with you during this period of time from midnight to 77 11 A No, not through that entire period. I volunteered to u stay on and I believe the rest of the people from Parsippany 13 all went back to the hotel to get some sleep.
It O Now at any time in this period from when you first 15 arrived at the site until any time thereafter, did you report 9
16 back to anyone in Parsippany what you were learning?
17 A No, I didn'4 no. I reported back, you know, that.
2 I had arrived and from-that point on I have no recollection of 19 having any conversation with anyone in Parsippany.
20 0 What did you do after you went back to the hotel?
21 You went back to the hotel and slept at 7 a.m.?
22 A Yes.
23 Q Did you go back to the site at any time after that?
M A Yes, I did.
25 0 And when was that?
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153 1 A I don't recall. I have vague recollections during 2 the day being back there, and then returned to the site in the 3 evening. I was at the site sometime during the day but I can't l 4 recall the time <nr duration. I must have gone back to the 5 hotel. I can remember having dinner at.the hotel and coming i
! 6 back to the site on the evening of the 29th.
7 0 Did you go back to the control room, unit 2 or the 8 observation center?
9 A I was at the control room unit 2.
10 Q Just let me make sure I have your movements right.
11 You left the observation center at 7 a.m. and went back to the El hotel to get some sleep?
13 A Somewhere around 7, I don't recall the exact time.
j 14 It was somewhere around that time.
15 Q You then at some point came back to the observation 16 center sometime in the afternoon?
17 A I don't recall whether I came back to the observation --
2 I must have come back there I guess to get permission to go on.
B My recollection is I did go on the island sometime during the 20 day, daylight hours on the 29th.
21 Q What were you doing at that time on the island?
22 A During the day I just have one recollection of being l 23 there, going up to the control room but I believe it must have
! 24 been on the 29th but I can't recall the details of it.
l 25 Q I guess what I'm asking you is in a broader sense, i
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i 154 1 what were you doing on the 29th, were you gathering information?
2 .A That's what I say, I can't remember. I presume that's, 3 what I was doing but I can't -- ,
4 Q Did you take any notes?
5 A I have no notes in my possession and I have no
-6 recollection of any.
- 7. O Do you know if you took any notes?
8 A I do not know if I did or not.
9 0 Then you went back to the hotel for dinner and you 10 came back in the evening to the control room, is that right?
11 A Well, I came back to the I guess you'd call it the 12 unit 1 administration building. I was there in preparation for 13 debriefing operators and at that point I was asked to-go up 14 to the control room.
15 ' O* That is the unit 2 control room 7 16 A That's correct.
17 Q Now, at any time in this period-from March 28th 18 through March 29th did you report back to Parsippany, and I'm 4
19 talking about after you made your call.at 2:00 or so to tell 20 them you were there?
21 A Well, on the 29th there were additional people that 22 had arrived from Parsippany and I was interfacing with them.
23 Q And who were those?
24 A The only one I recall was Dick Wilson was there and 25 I was interfacing with him.. ,
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155 1 -Q My question to you still, at any time do you remember 2 making any reports to Parsippany after 2:00?
3 A I have no recollection.
4 O Do you believe you did?
1 5 A No, I don't.
6 Q Are you certain of that?
7 A Certain as I can be from my memory.
8 0 You're not certain you made no contact with Parsippany 9 during that period of time other than the one conversation that ;
10 you've described?
11 A I've got no recollection of it and I've got no basis u to believe that I did-.
13 O Now, is it fair to say that'from the time that Mr.
14 Wilson arrived at the site you were reporting to him? -In'other 15 words, he being your superior?
16 A That's correct.
17 Q So essentially your reporting relationship would be 2 to or through Mr. Wilson at the point he arrived?
19 A That's correct.
20 Q Now, my question to you is did you report to anybody 21 whether it was, you know, I'm asking you now for some guidance 22 .perhaps on the relationship, did you report to anybody what!you 21 were doing after 2 p.m. on March 28th, whether it be somebody.
24 in Harrisburg in an observation center or somebody in 25 Parsippany?
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156 1 A I just can't piece that day together as to how things 2 went. I went back and got some sleep. Actually at that point 3 in time I recall the general perception on the 29th was over 4
with and do some interviews and go home so I guess it was --
5 O My question to you was from 2 p.m. on March 28 6 until Mr. Wilson arrived --
7 A Until he arrived?
8 0 -- until he arrived did you report back to Parsippany?
D A No, I said I have no recollection of being in contact 10 with Parsippany.
11 O Are you certain that you did not?
12 MR. BLAKE: Asked and answered, asked and answered, 13 asked and answered.
il BY MS. BERNABEI:
15 0 Are you certain?
16 A I have no recollection of having called back and I've 17 got no basis for believing that I would have called back so if 18 that constitutes certainty, then --
19 0 Did you report to anyone else; in other words, Mr.
- 3) Broughton or anyone else that was in the observation, Mr.
21 Broughton, Mr. Lentz, did you report to or through them to your Z! superiors?
Z3 A Like I say, I'm sure that I discussed all of this 21 or went over all this stuff with Gary Broughton, whether that E was related back to somebody else, I really don't know. j l
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l 157 I
1 0 Okay, now, would>you consider your making available 1
2 the information to him your reporting that information up, up 3 through your management' chain?
4 A I think I reflected before I felt there were other
.5 people available there.that were in communication. I did not 6 feel that what I had~was of that great import that --
1 7 Q Did you feel that you giving this information --
8 MR. BLAKE: Would you let the witness please finish 9 his answer.
10 MS. BERNABEI: 'He'wasn't answering my question.
11 A Well, I wasn't giving the answer you wanted.
O MR. BLAKE: Well, Ms. Bernabei, when you ask crisp 13 questions you get a crisp answer. When you ask broad questions 14 you'll likely get a broad answer and you ought to allow'the 15 ~ witness to complete it. ,
16 MS. BERNABEI: .
17 O Did you not understand my question,'Mr. Moore?
B- A What was the question again? "
B- 0 I thought it was a very clear question. If you don't 20 understand it~,s please tell me because I will rephrase the ,
21 question. -t l .
22 What.I'm asking ya2if you're making your' notes D -available to' Mr. Broughton on March: 28th, if you consider it
- 34. an act'of: reporting'to:your,. superiors, I thought that was a 25 very clear question? Is-that an active' reporting?
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15E 1 A No.
2 Q So you have no memory of reporting any information 3 you gathered to your superiors, is that right?
4 A That's correct.
5 Q Now, who in the observation --
6 MR. BLAKE: I want to observe that it is now 20 minutes {
7 of the 5 minutes of additional questions. How much more do 8 you expect?
9 MS. BERNABEI: I don't have very many. I have a 10 question on notes and one more question along the series of 11 questions.
E BY MS. BERNABEI:
13 Q Who in the observation center reported to Parsippany 14 to your knowledge?
15 A I don't know.
16 0 You know that they reported ~this information but you 17 don't know who they were?
18 A I know that there were people in communication with B Parsippany, I was giving them telephone numbers so --
20 . O Who were these people?
21 MR.-BLAKE:,-Asked and answered.
22 A -I said I don't recall.
-lD MR. BLAKE: Objection.
M BY MS.-BERNABEI:
25 Q* You don't recall if Mr. Herbein was: reporting to
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159 1 Parsippany?
2 A I don't' recall.
3 Q But you were sure that the information was going to 4 get through to your bosses, to your superiors, about what was 5 going on?.
6 MR. BLAKE: What's the basis for that?
7 A What information?
8 BY.MS. BERNABEI:
9 Q About what was happening at the reactor? You said 10 you didn't need to pass on information in your notes because 11 that information was already being given to Parsippany.
E A People that were a lot more knowledgeable.about the 13 situation than I was were in communication with Parsippany, 14 that's --
15 0 And my question is who were those people? If you 16 were so sure that they were giving that information, who were 17 those people?
4 18 A I don't know who they were.- I can't recall who they B were.
20 Q Were they people'in the control room?
21 A. I.was not.in the control room so I wasn't aware of
'22 what was. going on.
23 Q People in the observation center, right?
24 A 'Yes,.there.were people in the observation --
25 -Q And that'would have been Mr.-Herbein, is that right?
l
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160 1 A He would have been one of.the people in the 2 observation center. I can't recall if he was in communication 3 with Parsippany or not. i
~
4 Q It was he or someone underneath him, is that correct?
5 A It would have to be underneath him, right.
6 Q Do you know the names of one of those individuals 7 whether it'be Mr. Herbein or anyone else? You were so certain 8 this information was getting to them and yet you cannot name 9 any-of the individuals?
10 A I don't recall who was there. I remember Mr. Herbein 11 being there somewhere during the portions of the time that I E. was there but beyond that --
13 O Would it be your understanding that Mr. Herbein would 14 have passed on some information to Parsippany during this 15 period of time?
16 A I don't know if he was -- I don't know for a fact 17 that he was in communication with Parsippany.
B Q Let me ask you this, after thatLperiod of time did 19 it come to-your attention that in fact people from the 20 _ observation center including Mr. Herbein had passed on'this 21 kind of information during this period of time to-Parsippany?
E A No.
23 .Q You have no knowledge of that' fact?
M. A No.
25 0 You have no knowledge-of whether-or not people in'the
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161 1 observation center were giving information such as --
2 .A You're talking about something that's come to light 3 after the fact?
4- A I'm talking about after March 28th and 29th, it was 5 your feeling that information was being passed from the 6 observation' center to Parsippany had been verified?
7 A I had not attempted to verify it.
8- Q I'm not asking you:that question.. I'm asking you to 9 your knowledge was information in fact passed from the 10 observation center to Parsippany on the day of the accident 11 about conditions of the reactor, the type of information u reflected in your notes?
13 A I don't know.
14 Q You have no idea?
15 MR. BLAKE: Ms. Bernabei?
16 BY MS. BERNABEI:
17 Q You have no idea?
18 A I don't know for a fact.- I don't know, that's it.
B Q Do you know of any one communication you can identify 20 the individual involved between'the observation' center and 21 Parsippany between.the hours of 2 p.m. and midnight?
22 A No.
23 Q You don't know any communication?
St MR. BLAKE: Objection, asked and answered I don't 25 - know how many times; maybe a-dozen times.
.1
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d 162 1 BY MS. BERNABEI:
2 0 .Other than making your notes available to Mr.
3 Broughton, who did you make those notes available to? I'm
-4 talking about any-time after March 28th or Jth.
5 A After 28th and 29th?
6 MR. BLAKE: Any time till today?
7 MS. BERNABEI: Any time till today.
8 MR._BLAKE: Ms.'Bernabei, can't you ask a more 9 relevant --
t 10 A I turned-them over to the documentation people.
11 BY'MS. BERNABEI:
E Q. You mean within the. corporation?
13 A Right.
14 Q Is that a special division?
15 A It was a' group set up to collect information after 16 the accident.
17 0 Okay, this was an internal GPU investigation?
18 A It was an internal'.GPU group.
I don't know if.it was B an investigation. -
20 MR. BLAKE: Objection,. asked and-answered.-.The same-121 .subj ect earlier covered. It's now 25' minutes into our 5 minutes 22 ' of additional questions.
Z3 -BY MS. BERNABEI:
34 Q This'is the.groupJthat Mr. Long was a part, is'that 25 right?-
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161 1 A It's my understanding he was.
L2- Q Okay. -Did you ever turn over your notes to Mr.
3: Arnold?
4 A Not.that I know. I didn't personally turn them over 5 to him.
6 Q Do you know if they were turned over?
7 A 'I.believe you showed me.someth'ing.here today that
~
8 .would indicate that they were.
9 Q H'ow about Mr. Keaton? To your knowledge were your 10 notes ever turned over to Mr. Keaton?
11 A I have no knowledge.
E .Q How about Mr. Wilson?
13 A- No knowledge.
14 Q Mr. Croneberger, your. superior?-
15 A No knowledge of that.
16 . O So you have no knowledge that anybody-.but.the 17 _ documentation people.got them, right?
E' A That's all I'm aware of, yes.
19 Q And you kept.a copy?
20 . A As .I recall: they turned the = notebook over to him 21' and they returned a copy.to me.
12 - Q .Now, I'have one question on -- going back for a 23 moment. .When you first went to the site and you were not.
~ ~
Si permitted to go on the site, who gave you~that direction that 25 you not'be permitted ~to go to the controls?
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1 64 1 A The state policeman.
2 O And where had they gotten the authority to keep you 3 off the-island?
4 A I didn't ask.
5 Q Well, it had to'come from some Met Ed person?
6 A Well, when the policeman said I can't go on the 7' site I --
8 O Well, did you try to get on the site any time after 9 that?
10 MR. BLAKE: At any time after that, Ms. Bernabei?
11 BY MS. BERNABEI:
02 Q March 28th.
13 A No.
14 Q Did you inquire as to who had given the order that you 15 not be al-lowed in the control-room?
1 16 A No, I didn't.
17 Q Do you know now who if anyone had given directions 18 - and I'm now talking about anybody within Met Ed or GPU had 19 .given orders that-you not be allowed in the containment 2 20 control room?
- 21. A No.
22 - Q You have no information about any order of that sort?
23 A- No, M O Other than these notes, do you recall any other-notes 25 that you wrote on March 28th, March 29th or March 30th?
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165 1- A March 28th I did some calculations, the 29th 2 hydrogen calculations were made sometime~just prior to mid-3 night, something like that.
4 Q That was with Mr. Capadonno?
5 A- That's correct. The 30th, more hydrogen calculations, 6 Q Okay, now, --
7 A Let me see, and I believe there was a note dated 8 the 30th with respect to the pressure peak.
9 Q The one that is attached to your questionnaire, is 10 'that correct?
11 A That's correct.
U2 0 Is it your usual practice to maintain notes fairly 13 consistmt WLth the information or the meetings you attend during 14 a day,?
15 MR. BLAKE: Objection, asked and answered.-
16 BY MS. BERNABEI:
17 0 Is it usual practice in meetings or in discussions M. to take notes, that's what I'm asking?
m A Yes, m Q And you do that on a consistent basis, I mean that's 21 in your. usual course of business, in your usual course of 22 events you would do that?'
23 A. If 'it was something of-importance.
2 Q. Now, it's fair to'say
- hat-there_are no notes from 25 March 28th other than -- well, did you take any other notes
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166 1 other than the ones we see here, these ten pages of notes?
2 MR. BLAKE: Objection, asked and answered. It's now 3 a half-hour into our extra five minutes of questions.
4 A I think I had some notes about the -- let me see 5 what did I have. I think I had some brief notes about some
- 6. of the Foust, Fredrick=but none of them relate to the hydrogen 7 leak or anything like that.
8 BY MS. BERNABEI:
9 Q Do you have those notes today?
10 A I don't'have them here.
11 Q Anything for this period of time now?
E A Which period of time?
13 Q The period of time the notes cover which is about 14 say 9 a.m. I think by your representations until sometime 15 after 7.
16 A The only other thhg up through midnight would have 17 been the calculations of the leak rate.
B Q There were no notes then fromtthe meeting -- after 19 the meeting at- 10:05 a.m. until ~this briefing at 5 p.m.?
20 A That's correct.
21 MS. BERNABEI: Okay,.I have no other: questions.
22 -CROSS-EXAMINATION 23 BY MR.-BLAKE:
34 .Q' Mr. Moore, your-testimony generally is that you have 25 little recollection beyond'that which is reflected'in your notes
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167 1 'which were taken contemporaneous 1y on March 28th on this 2 subj ect _ of Ms. Bernabei's questioning, is that generally 3 correct?
4 A Yes, it is.
5 0 With respect to hydrogen, the pressure spike, 6 generation of hydrogen, combusion of hydrogen, however your 7 answers have been that you were not aware of March 28th, is' 8 that correct?
9 A That's correct.
10 Q -What leads you to have more conviction today about 11 your lack of knowledge of the subject areas, generation, E combustion of hydrogen, the pressure spike and that you had 13 no knowledge of those on March 28th than in other areas where 14 Ms. Bernabei was asking questions?
15 MS. BERNABEI: I'm going to obj ect. I think you're 16 mischaracterizing his prior testimony.
17 MR. BLAKE: Well, he's certainly capable of answering E- whether or not I've mischaracterized it.
19 LBY MR.~BLAKE:
20 0 Have I mischaracterized your testimony, Mr. Moore?
21' A I don't believe. .I.think that reflects what I have 22 tried to convey.
23 - Q_ Would you answer the question,.please?
24 A' There are two points in time, one on the 29th and is one apparently on the 30th, I have vivid recollection of two
- GEIGER a LORIA REPORTING SERVICE. INC. 1000 MART (ET ST H3G. PA 17101 HOG. 234 2109 PA 1.OOO.222 GLRS -
168 1 things. happening. The 29th I have recollection of going up to f
2 the control room and met with Bill Lowe and he informed me that 3 he suspected that.we had hydrogen in the primary system. And 4 I can recall the surprise of hearing that and if I'd of had 5 prior knowledge of that, I wouldn't have felt that or had 6 that reaction.
7 .The second point I can recall -- I can't recall it 8 happening, I can't pinpoint the time, my notes. reflect it 9' happened on the 30th;-- was someone showing me either the 10 actual. trace or a copy of the trace of the reactor building 11 pressure spiking up and down and that was another time'of u reaction of surprise. So based on my recollection or'my 13 reaction to those two events, I have a great degree of certainty 14 that I was not previously aware of either the presence of 15 hydrogen in the system or the' pressure spike or the' extreme 16 pressure spike.
17 MR. BLAKE: Let the record reflect that Ms. Bernabei 18 and Ms. Doroshow are laughing or smiling at each other and 19 might I ask them why and whether or not they regard that as 2 appropriate.
21 MS.-BERNABEI:. I have a few questions to ask him 2 that will probablyfexplain the basis.
m MR. BLAKE: Would you care to answer.my question?
M MS..BERNABEI:. No, but I'would.like to ask Mr. Moore 25 a few questions and it may explain the basis for our amazement.
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169 1 I didn't'mean' to interrupt you.
2 A That's' basically it.
3 MR. BLAKE: I have no more questions.
4 REDIRECT EXAMINATION 5 BY MS. BERNABEI:
6 Q Is it fair to say, Mr. Moore, from March 28th there 7 were a great deal of things you did not remember, is that fair 8 to say?
.9 A That's correct.
10 0 It was a long time ago, is that fair to say?
4 11 A Correct. ,
C Q It's also fair to say that in' terms of your career 13 and the nuclear industry these couple days were pretty 14 significant, it was a pretty serious event, it was a pretty 15 significant' event? .
16 A That's right.
17 O However, you don't seem to remember a lot of things 18 that happened'on March 28th, is that-right?
B A Well, there's a lot of~ things I-don't remember =
20 whether they happened or not.
21 Q Well, you don't remember'who-was at meetings?
-:2 A As far as remembering people involved, that's right.
23 - Q -You don't reme'mber if.you talked to-Bob Arnold on 24 March 28th, is that right?
25 A That's right.
- GEIGER & LORIA REPORTING SERVICE. INC 1000 MARKET ST HgG. PA 17101 MSG. 234 2109 PA 1000 222 GLRS -
170 1 Q You don't remember exactly what your assignment was 2 when you were down at Three Mile Island?
3 A I think I reflected what my assignment was.
4- MR. BLAKE: That's not a fair characterization of 5 the witness' prior testimony.
i 6 A' I had a.very specific assignment when I was dispatchec .
7 'BY MS. BERNABEI:
8 Q You don't. remember;who dictated or gave you that 9 information you recorded-in your notes at 5 p.m.?
10 A No, I don't.
11 O You don't remember anyone in the observation center E! who.was in contact with Parsippany?
13 A I don't recall the names or the faces.
14 0 You. don't recall any particular time on those two
- 15 days, March 28th or 29th, that you talked to Parsippany?
16 A I recall the time when I called back and reported 17 that I had arrived. That's the only time'I can recall.-
18 Q But yet you remember with great vividness these B two occasions on March 29th and. March 30th?
20 A Yes,.I do.
21 Q. Those are crystal clear in your mind?
=. 22 A Right.
23 -Q Okay.
M A As.well as other. points in time but those two in 25 particular stand out in my mind.
- GEIGER & LORIA REPORTING SERVICE. INC 1000 MARKET ST HSG. PA 17808 HSG. 234 2109 PA 1800 222-GLRS -
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' 171 1 MS. BERNABEI: I have no other questions.
- 2. (Whereupon, the deposition was concluded at 3 3:10 p.m.)
4 5
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- 20 21 22-23 25 :
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- I ,
177 l' I'N D E X I. 2 WITNESS i 3 FOR GOVERNMENT 4 ACCOUNTABILITY PROJECT DIRECT CROSS REDIRECT 5 James:P. Moore, Jr. 2 166 169 6
7 8
9
. 10 11 EXHIBIT
- 12 PRODUCED 13 DEPOSITION EXHIBIT NO. AND MARKED
. 14 -1 - Cover letter with handwritten noties 17 15 16 17 - .
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- SEl6ER & LORIA REPORTING SEINICE. INC 1000 MARKET ST MSG. PA 17101 HSG. 234 2109 PA 1000 222 SLRS -
n----1. ---_ _ _ - - - - - -- -- -- -s-s - a --.-.-
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1 COUNTY OF DAUPHIN :
ss 2 COMMONWEALTH OF PENNSYLVANIA :
3
.4 I Ellen Swayze Reisser, Reporter-Notary Public, 5 authorized to administer oaths within and for the Commonwealth 6 of_ Pennsylvania and take depositions in the trial of causes, 7 do hereby certify that the foregoing is the testimony of 8 JAMES P. MOORE, JR.
9 I further-certify that before.the taking of said 10 deposition (s), the witness (es) was (were) . duly sworn that 11 the questions and answers were taken down stenographically _by a the said Ellen Swayze Reisser, a Reporter-Notary Public, t 13 approved and agreed to, and afterwards reduced to typewriting 14 under the direction of the said Reporter.
15 I further certify that the proceedings and evidenca 16 are contained fully and accurately in the notes taken by me 17 on the within deposition (s), and that_this copy is a correct 2- transcript of.the same.
s In testimony whereof, I have hereunto subscribed my 20 hand this- 1st day of October, 1984.
21 22 /kr E /!4 E MJt---
Ellen 23 Notary $way%e Public Reisser, Reporter 24 My commission expires on June 8,1987 25
- GEIGEll e LORIA REPORfl90G SEWICL IfeC., t000 IIANKET ST-MSG. PA 17101 NOG. 234 2109 PA I 400 22& GLR $ -
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Intcr-Offico lks,..m2randum Septemb'er 17, 1980 Date E&L-2794 mem e , ,s
( 4~ LJ INTERNAL WORK RELATED TO GPU'S > r f Se;e:t KNOWLEDGE OF CORE DAMAGE FOLLOWING
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/* ' . l THE TMI-2 ACCIDENT File: 2359.' i ~. ...'.
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To Vice President - Generation Locar:on Headq rters 2 '.M0 > j*
R. C. Arnold ,
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5 I have attached for your information three papers Nhichla* %r6 the only items that I am aware of related to our understanding of the core damage following the TMI-2 accident. The draft TDR-ll5 was the initial effort undertaken by John Hilbish. This TDR was never approved or completed. The interview memorandum of Brian Mahler was done in connection with investigations by R. W. Keaten's Task Force. I have not provided a copy of the Keaten Task Force Report, which I believe you have. The untitled piece reflects the complete efforts of Bill Behrle, Scott Guilbord and Don Reppert that was undertaken at your request of about December of last year.
This document was never formally transmitted within the company, but was prepared in anticipation of other investigations, which did not materialize at the time prepared.
I have talked with Bill Behrle about the effort he was in-volved in to see if any other material was available. He noted i
that, in preparing his work he and the other members filled out a matrix, which reflected the interview records they reviewed and the subjects of interest contained in that interview. Bill is searching his records and will forward a copy of the matrix, if found, to you separately.
I know of no other work complete, or incomplete, that would-have any further bearing on this issue.
(k/ w E. G. Wallace Licensing Manager EGW:bjo Attachments cc: E. Blake, Esq. - w/ attach.
B. Behrle - w/o attach.
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EL4 2559. . Y I. Core Damage / Fuel Uncovering From a reading of the depositions and interviews, it is obvious that '
both the licensee and the NRC knew on Wednesday, March 28, that core dam-
. s age and fuel uncovering had occurred. However, the severity of the dam-age was not
?
realized until-the results of the primary coolant sample were received on Thursday 3/29.
. A. Licensee's Knowledge'
- On Wednesday, Chwastyk (Shift Supervisor) was _ aware of high incere Thermocouple readings, assumed there was some core damage, l
realized magnitude of problem idien it took 50,000 gallons of HPI to fill the 88,000 gallon RCS, and knew there was core damage i,
from the explosion in the building. Frederick :(Control Room -
- Operator) was concerned about possible core uncoverage and twice suggested full HPI. Frederick and FaNdt . (Control Roma Operatori later initiated HPI after PORV isolation, but were -told by some-one out of th,e Shif t Supervisor's Office to secure HPI. Flint (B&W Physics Test Coordinator) believed' core had been uncovered ,
4 or had voiding due to increase .in . leakage flux. Flint told.
i Rogers'this around 10:00 a.m. (Rogers does not remember this, but.Kunder does,),
. 4 Flint thought extent of damage was a rele,ase of gap activ-ity.Hitz (Shift Supervisor) realized failed fuel at 6:50 a.m.
when someone yelled-600R/hr.lin sample line (really _was 600er/
hr.)~. ' Kunder (Unit Superintendent - Technical Support) felt
- ~
the core ~had.been uncovered _due to;the impression he-got from-Porter that some of the core contained superheated steam.
Kunder also said that when the-reactor coolant pump pumped 1
e f
n + - , . , . . r v.-.#-iv,- %,,bwa--, , . - - , 2
,-.,,-% y;,w-i w --. 4 aa e r , w y-- rr--m y- syw . - = , 9 ,<yw---w ,,.-,v, , *g4-e
steam, everyone was concerned that the core might be uncovered.
Logan (Unit 2 Superintendent) knew the core was damaged at
- 6 :40 . a .m. Mehler (Shift Supervisor) felt fuel failure occurred at 6:45 a.m. when radiation alarms came on, and, prior to this, f
wasn't sure whether core was completely. covered. Miller (Station Superintendent) realized we had failed fuel (gap activity) at 7:05 a.m. when he entered the control room. However, he has t .
l made several conflicting statements about core coverage. Porter
] (Instrument Engineer) learned of failed fuel when the site emer-gency phone calls were being made. Porter recalled no conversa-i tion with anyone regarding core coverage, which . conflicts with
~
Yeagerwhosaidhediscussedthiswith'Porteraround8:05a.m.
, Rogers (B&W Site Manager) did not believe core ~had been uncov- ~
ered since a large volume of water did not come out of core f flood tanks when they were floated on the core. Ros s . '(Opera- !
tions Supervisor - Unit 1) knew'arount 7:00 a.m. that we had-failed fuel, but didn't consider whether core had been uncov- .
ered. Seelinger (Unit-1 Superintendent) believes that-it en . ,
tered his mind on Wednesday that the core had been uncovered.
Yeager (Instrument Tech.) told Porter around 8:00 a.m. that-
'- he thought the core was uncovered based on high thermocouple l - . - readings. Porter.does not recall this. ewe (Shift Super-l visor) did not' think (on Wednesday) that the core was uncovered.
Arnold (Vice President.- GPUSC Generation) first become con -
~
4 cernedI of cladding / fuel failure .aroundl8:00 a.m. when he re-i .ceived high reading on the: dome monitor, and was. continuously concerned on Wednesday as to whether or'not the.. core was covered. He was'first concernedEvith 'significant fuel' damage -
t
.M M
E 1
t I l
j
.on' Thursday morning. Creitz , (President - Met-Ed) told Dieckamp ~
\
t (President - GPUSC) at 9:30 a.m. of-Arnold's concern of possible Herbein (Vice President - Met-Ed ') l damage to the fuel assembly. '
Generation) talked with Arnold early Wednesday morning about lking to Miller t
_ possible fuel damage, and concluded af ter ta He believed later in the morning that we had some failed fuel.
=== ,
the core had been covered'when he received the results of the e I
Herbein said that core flood tank level change upon floating.
- t. ~
up _ until Wednesday evening, the plant staf f believed the core 1 f l was covered (conflicts with statements of numerous plant staf l-i members).
He received the high reading from the primary coolant sample on Thursday, and briefed the pre s that we had failed fuel.
i
+ B. NRC's Knowledge l
' Gallina (site) knew on Wednesday that there was core dam-l age, and believed on Thursday that there was gross fuel damage He based on the 1,000R reading of the primary coolant sample.
said that whatever the licensee or NRC on-site team knew, it.
was immediately available -to Region I and to NRC headquarters.
Baunack (site) said neither the licensee nor the NRC realized the severity.of the problem until the primary coolant sample i
'was taken Thursday night. He said that the NRC was totally 1
aware of and informed of everything' going on. .Mosely felt .
Jon Wednesday that there wasl core damage, but.didn't know it-
- was extensive until the primary coolant samples were obtained i ,
on Thursday. . Stello (Bethesda) beco'me aware of extensive
~
core damage on Wednesday, EandLfelt'it should'have been aware to everyone.-
Both Vollmer and Stello realized on Wednesday that the core had been uncovered.
b- y
+ tt w~~'-r .cr -w' -s~ ' N- -s-A'+s er
- Me-=+w*N'~'s --Om Wv 's *-*n~ ****~f
I Maggie Reilly (PaBRH) to'1d the NRC Regionn I at 10:45 a.m. *
's
- that B&W representatives believed that fuel assembly gap activ- ',
, }
icy had been released, but that th e n, .'had been no fuel melting. 2
- Hitz (Shif t Supervisor) vaguely remembers a conversation with Stello en Wednesday about the core being uncovered or in a super- ,,
) u 14. ',.'. . L Js . . ,
heated ' condition, and about the' floating of the core flood told *LA nd. .e ** *' y
- A ' '**
- 4 Hitz that this would not guarantee core coverage and Hitz no-tified Unit 2 between 4:00 and 4:00 p.m. of Ste11o's concern.
Hitz does not remember who in Unit 2 he spoke with, and Miller .
was never aware of Stello's concern. Kunder (Unit Superinten-dent - Technological Support) notified Haverkamp at NRC Region I Office of failed fuel and curtailed HPI at 9:35 a.m. on Wedneday.
t d
e
.- ~ ,- . - -
- . , 61 .
II . _ Pressure Spike / Hydrogen
- Several of the licensee's employees were aware on Wednesday of a
- real pressure spike, while others were not. A few of the licensee's
- employees were aware of an instrument indication of a pressure spike, but.they attributed it to an instrument. or electrical malfunction.
,t Other. employee's 'wh'o heard loud noises -(thuds) attributed them to the cycling of ventilation dampers. Those who were not aware on Wednesday of an actual' pressure spike learned about it over subsequent days.
- Two of the licensees employees .(Chwastyk and Mehler) who were aware of an actual pressure spike may have believed on Wednesday that it was due to a hydrogen explosion. If they did then believe this, it.does not
- i. appear-that they communicated their belief to anyone. The-remaining employees who were aware of.an actual pressure spike did not associate
- it with hydrogen on Wednesday.
T'h e earliest that the NRC appears to have become aware of both the i
pressure spike and the hydrogen explosion was-Thursday, although one of the licensee's employce's (Chwastyk) says he mentioned the possibility-of an explosion to.an NRC man in the control room on Wednesday, and another employee (Mehler) says he pointed out the spike to an NRC man in the control room on Wednesday.
. 1
'A. Licensee's Knowledge --
- +
Chwastyk saw pressure. spike occur and. thought it was an '
4 instrument malfunction until the spray pumps came on. 'Chwastyk
, said he put together cycling of block valve and pressure spike, '
and told Miller' that spark from valve caused explosion and asked Miller for permission to draw a bubble and repressurize i
(Miller-does not remember ~this). He assumed the explosion was caused by hydrogen,' but may not have related this to Miller.
_-..-_.______-_-__---.:_._________._-.2--___ _ . _ _ . - - - - . - - _ - - - . _ _ . - - _ _ - _ . . _ _ . _ . - - _ _ _ _ - - _ _ - - _ - _ - _ _ _ _ - . . . . . - _ - - - _ _ - - - - . - - _ _ _ _ _ - . - - - _ . _ _ _ _ _ _ _ _ - . - _ _ _ _ _ . - _ _ - . -__-_-.----_~_-___.L___
w (Miller does not remember this). Jht assumed the explosion was ,
i caused by hydrogen, but may not have related this to Miller - t.
(Miller does not remember this). Frederick saw pressure spike occur but did not know what caused it. He saw pressure come f back down to normal, perceived-no consequence, and continued on with his functions. On Thursday he learned that the pres-Flint. heard a surg,gpike was due to a hydrogen explosion.
double thud and thought it was the ventilation dampers cycling.
The high pressure instrument indication was believed to be an electrical or instrumentation malfunction. He had no reason to believe there was hydrogen present. Kunder was concerned (he's not sure if it was Wednesday) about energizing electrical equip-I ment due to long-term generation of hydrogen from aluminum. He 4,
was not aware of the prercure spike until Friday. Logan heard I
l a noise and was told (thinks Miller told him) that it was the ventilation system cycling.. Marshall knew of pressure spike indication and said the consensus of opinion was that it was due s ~
Mehler said he saw pressure to instrument or electrical fault.
spike and that he told Miller and Ross in Shift Supervisor's
Office of spike (Miller and Ross don't remember this; Miller and j
Ross were in the' Control Room at the time). Mehler said in his August statements that he discussed the possibility of a chemi-cal reaction with Chwastyk and that hydrogen could have been
. Later,-
mentioned (Chwastyk does not remember this conversation).
in October, Mehler said thacLhydrogen was definitely not con-sidered on Wednesday, Chwastyk did not mention hydroden on Wed-nesday, and that he'(Hehler) did not hear of hydrogen until it
- 4 5
Y
, .. _ . . . _ . , _ - . , , . , . , . , _ _ , . - . . ~ , . _ . -
~
. came out in the press. Mahler said he thought Miller gave; order g on Wendesday not to start motors (Chwastyk, Miller, Rose5 and i'
Newe all told him in discussions that it was on a later day).
1
~
. Miller heard a thud and was told it was the ventilation dampers
\
[ cycling and did:not know on Wednesday 'that it was a real pressure l spike.. He learned from Bill Lowe on Friday of hydrogen detona-
/: I t
tion. Porter _did not know about pressure spike until Friday ,
morning when it became " general knowledge," and later'that morn- '
l 4'
ing was' asked by Miller to look at recorder charts.(Miller
~
4 remembers this).- Ross said he and Miller had their attention called to the pressure : spike by S' eve (M111d'er doesn't remember ;
!. this, and 5 ewe doesn't remember discussing it with Miller). He i [
j said.they figured it was an electrical malfunction or else they i
- didn't understand it,'but it was not considered important because pressure returned to normal. Seelinger heard about pressure spike ;
7, .
some time after. Wednesday. J6 ewe saw presure spike, discussed it with Chwastyk and Ross (Ross remembers this), and they concluded s.
! it was some sort of electrical' transient. Newe did not percieve 1
on Wednesday that there was hydrogen in the building, and did not i
j- lea,rn unt,il Thursday that a hydrogen burn caused the spike..
Arnold did not learn'of pressure spike until Friday morning, and
- does. not remember whether he thought the then-existing bubble
- ett.-
contained hydrogen. Herbein became of. pressure , spike sometime j -
..a....s
.between . Thursday and Saturday,;and the con, current analysis by Bill Lowe' indicated to Herbein that we had 'had a hydrogen burn.
s B. NRC'S Knowledge i
i Gallina in his May 7 interview said that, on Thursday, the-f NRC believed the pressure spike was hydrogen but that Met-Ed did-i.
4
. - - _ . _ . . . _ . - . _ , , , _ . . _ _ . . _ . - . ~ . _ - . _ . _ . _ . . _ , . . -_ - .
, . y ,.. '
{? 3, +
p.
not. Later, in his May 31 interview, he said he ' first became ' '
4, t
~
aware of Wednesday's hydrogen e ' xplosion on Friday, and that it-
- E was late Thursday or early Friday' that the NRC inspectors in "
- 1the Linit 2 control room were told of the pressure spike and a possible hydrogen b'rn.. u Baunack said that ~the primary coolant . '
l . sample received on Thursday indicated serious core damage, and e
c prior to then Noone had realized that the existing bubble could.
i 1
-be a hydrogen bubble.- Higgens said that the control roca was
/
so busy that neither he not plant. management realized until-Friday..when they went ov'er tho' charts, that a. pressure spike i had occured on Wednesday. The NRC Incident Message Forms in Region I show that at 3:12 a.m. on Friday, the NRC completed j their experiments and ~ estimated the size of the bubble -at j' 5:55 a.m. they concluded that it;was a hydrogen' bubble. and at s
5 9:00 a.m. Ray.aond (NRC-site) told Region I,that hydrogen was-t l
l what had caused the pressure spike (detonation)' on Wednesday.
Chwastyk says he told an NRC man on Wednesday--that he i
thought we'had an explosion.- Mehler recalls telling an NRC 4
I man in the control room on Wednesday of the pressure ' spike.
1 I
^
Se ,
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1, ,
r I
I l
I 3- ,
e l
4 2
. _ -_ .- . - , . - . . - --- ~ . . -
171. In-Core Theraccouples A. Licensee's Knowledge
- The in-core termocouple readings prin: out on sheets of the *l i
control room computer. On Wednesday morning, many of the thermo-couple readings were off the high end of the computer's scale (over 700*F). In an attempt to get actual temperature readings, ,,,
i several maintenance and instrument people went to the cable room where the thermocouple lines fed into the back of the computer. Of the four thermocouple readings taken with a fluke thermometer, two were unusually high-(above 2300*F) and two were unusually low
. (slightly above 200*F). The Emergency Director (Miller) was in-formed of these readings. Most employees who were aware of these four readings found them confusing and inconsistent, and therefore
- unreliable. One technician (Yeager) said he told an instrument i
i andcontrolengin$er(Porter)that,basedonthehighreadings, he thought the core was uncovered. A second set of readings 4
taken with a digital voltmeter at about 8:50 a.m. confirmed the
-first four readings - some were extremely high and some were ex-treme,1y low. While the presence of low readings was puzzling, ,
l the fact that the second set also contained extremely high :
I readings convinced the other technicians of probable core uncovery. j However, the instrument and control engineer (Porter), who was serving as the liaison between the technicians and the Emergency Director'(Miller), forgot that the second set of readings had.
- i been taken. Therefore, the Energency Direcotr may never have - !
..
- 1 been informed of the second set of readings"adn the engineer #s ,/ !
- J l conclusions,.' JMereby he might have determined that the core had j been uncovered.
p
- y. '
A similar breakdown in. communications occured Wednesday . ,,
- morning involving the B&W site' engineer (Flint) and his l'iaison- '
(Rogers) with the Emergency Director (Miller). The B&W s'ite engineer reviewed the in-core' thermocouple computer printouts o
.(most were off scale), along with-other information concerning I ~ the course- of events, and between 10:00 and' 10:30 a.m. con-j - cluded that the core had been uncovered - t se was no longer un- a covered. - The B&W site engineer recalls informing his -liaison of his conclusion, but the liaison doaf not remember such a i
l t.
conversation. It therefore'again appears that the Emergency Director was not informed of an engineers evaluation of the i & '
in-core thermocouples which le,t to a determination that the -
?
! core had been~ uncovered.
In any event, the Emergency Director (Miller)' knew of
~
I 1-the first set of readings where two reading were off-scale high. His liaison (Porter) with the technicians told his t' :
that if the thermocouples had gotten really hot, they eight '
have melted and formed other junctions whereby the readings i
i would be unreliable. As 's result, the Emergency Director I .
l has' stated that in in-core thermocouples were so hot that l' .
they scared you and from that he knew we were super heated.
However, he had also stated that due to the wide disparity.
j .
in the few thermocouple readings he received, he did not l l
I believe that any of the readings were reliable and he did i . . .
- ,,not pause to consider their significance.
- 4
, - B., NRC's Knowledae-i
- The director of the-NRC's THI Support Task Group and-i~ acting assistanh director of NRC's Systematic Evaluation-c ,
l v
- .7
, - - , , , , . . . , . . < - , n x--., , , - - , , , ~ - - , . - , + - - . . , - . , , , , ,
..na,- ,,---m-v...-w-,w-.~, + , , ,ce,,-.-...n.,,, ,wm.- wv. ,. n---n,--,.-_e.
t z, Prcgram (Vollmar)- kn1w an LWidnssdcy thet the temperature, in the l
^
hot leg: above' the core were higher than the saturation tempera-
^
.'tures of the liquid (and concluded the core was superheated and *
.therefore had been uncovered). The director of NRC's Office of -
Inspection and Enforcement (Stello) has testified that atqabout
, 4:00 p.m. on Wednesday, when he was at. the Incident Response l
. Center (IRC) in Bethesda, he was informed that the computer e i b in-care thermocouple data was mainly questions marks, from 1-l which he: 1) correctly inferred that Tthe temperatures -were
[t - off-scale high, 2) felt it would be pr dent u to believe that the t
thermocouple readings indicated superheated steam, 3) felt the
! Licensee should believe that the core was uncovered, despite i pressurizer level indications and 4) called the TMI-1 control f room and told them that the operator should understand clearly i
- that the core is uncovered because the temperatures were too high.
ji However, the NRC tapes clearly. show that it was a T-hot
- temperature (rather than thermocouple readings) of 550' degrees -
with a pressure of 450 pounds which led Stello to this con-l clusion, and that he did not know at this' time that the in-t s
core thermocouple readings were off-scale high.
i The NRC , tapes also show that at 10:15 a.m.~,.Haverkamp i . (NRC-Region I) asked and was told that the T-hot was off-i *
- scale high (over 620*), and at 10
- 30'a.m. he'wa's told that 2
j . .
T-cold was extremely low (about 220*) . : ' At 2:15 p.m. , .
1 Capthon (NRC - Region I) was told that the T-hot was 600*.
The whole center of attention by the NRC with regard to T. ,' d ' "
l - was.T-hot and T-cold and the licensee was continuously re- -
questedbytheNRCtoprovide,anddif1' provide,this l
information.
1-
, .,---,,,y -, ve- -
e 't' " - - - = ' ' w- w - - n,-- -w---+- e w w- z+ +--w' w'*v v e m- *-"=v='vw-*--e -,++--*T+* * *W +-F- mw - ^v--*--
l Although Wilbur (NRC - B'ethesda) indicates that it was '
Wednesday morning, our reading of the documents show that it ,
was not until around 4:05 p.m. on Wednesday that Wilbu. (or anyone else from the NRC) requested the licensee (Hitz) to i
- get in-core thermocouple readings. At 4
- 10 p.m. , Wilbur was told by the licensee (Hitz) that the computer in-core thermo-e, couple data was printing question marks. -
The licensee (Hitz), unaware of the readings taken Wednesday morning in the cable room then told Wilbur that the question marks meant that either the computer point was t
" messed up" or that the sensor line was broken. The licensee (Hitz) also stated that we were trying all of the in-cores to see if any of them would print, and that this would take some time.
3 At 4:30 p.m., Higgins (NRC - site) communicated a T-hot temperature of $80* to Wilbur. At 5:15 p.m. and 5:45 p.m.,
Higgins again communicated this temperature to WL t (NRC -
t Bethesda). Higgins communicated T-hot and T-cold temperatures to Witt and Haverkamp (NRC - Bethesda) at 6:00 p.m., 6i12 p.m.,
' ~
! 6:45 p.m. , 7 :00 p.m. (T-hot 560*) 7:10 p.m. (T-hot 557*),
- ., 7
- 20 p.m. (T* hot 560*) and 7:36 p.m. (T-hot below 520*).
, At 7:56 p.m.,
Smith (NRC - Unit 2 Control, Room) cold 4
Cagliardo (NRC - Bethesda) that they were still unable to read any of the in-cores and that they would still try to get some to print out. A reactor coolant pump had been started at 7:46 p.m. and at 8:07 p.m. Baunack (NRC - Unit 2 1 Control Room) reported to Cagliardo that the in-core thermo-couples were then reading with a high of 611* and a low of
_ . - . , . . . _ , . _ _ _ , _ , ,_ - + - ~ .
=+ . .
s 'y' 254 * , but that these were random readings and probably useless.
0 Around 8:45 p.m., Baunack told Wilbe- that T-cold was 320* and pressurizer temperature was 520*. At 9:15 p.m. , Baunack told headquarters that the in-core thermocouples were not really reliable.
In summary, the NRC concentrated on T-hot and T-cold a
temperatures throughout Wednesday, and even when'they got actual in-core thermocouple readings they doubted their re-liability and usefulness and did not utilize them for determ-
- ining system or core conditions. It was not until 1
- 30 a.m.
I on Thursday that the NRC began to give credibility to some of the in-core thermocouple readings and plot them on a core grid. However, Raymond (NRC - Unit 2 Control Room) in re-laying this data in Bethesda noted that the high numbers (617*, etc.) were questionable since the engineers had told i
, the operators, who in turn told Raymond, that some of the thermocouples were probably damaged through the transient.
At 7:30 a.m. on Thursday, Raymond relayed 38 of the 53 pos-j sible in-core thermocouple readings to Bethesda (the re-maining 14 were unavailable). At 11:00 a.m. on Thursday, i Raymond notified Bethesda that he had notified the licensee i -
that the NRC had )een tracking the in-core thermocouple i
i readings and that Met-Ed should do the same and either, i
- l. verify or discredit the in-core thermocouple readings.
.It therefore appears that even by this point in' time the
.NRC was uncertain of the validity of the in-core thermcouple -
readings which were actually printing out, and was not i t!. .i -
relying on ,tme to assess plant conditions.
s t
, .i IV. Calculated Dose Rate of 10-40 R/hr in Coldsboro The highest dose rate which was calculated for Coldsboro was 20R/hr.
- l. ~
This dose rate was a predicted dose rate, based on a hypothetical worst-F . ,
case situation where one assumes a containment building pressure of 55 pounds and a leak rate of .2% per day of the containment building volume I
(2.3 million cubic feet). At 7:44 a.m. on March 28, the dome monitor ,
(HP-R-214) was properly read and the predicted worst-case dose rate was ""
calculated to be 20R/hr in Goldsboro. Thereafter, the wind speed in-creased from 2 to,3 miles per hour, resulting in a correction of the i l
{ predicted calculated worst-case dose rate from 20R/hr to 10R/hr for
{ Coldsboro. The corrected calculated dose rate of 10R/hr was then com-
! T -
1 municated to Dick.Rubiel (Supervisor - Chemistry and Radiation Protection) 4 r
at 7:46 a.m. However, over the next few minutes, actual field data was received enabling the engineers to calculate reat-case dose rates as opposed to the hypothetically predicted worst-dose et.tc def ' for Coldsboro.
rates By 7:50 a.m., the real-case dose rate for Goldsboro was calculated to l 1
be t- 1 millirem /hr. As a result, the 10R/hr predicated calculated '
4^
worst-case dose rate was high by a factor of 10,000/10R/hr) i (lar/hr/andwasnot reported since it was negated and made meaningless by the 1 millirem /hr j
i calculated rea'l-case' dose rate. '
The 1 millirem /hr calculated real-ecse cl _ I.
j dose rate was reported by Dulid to the State around 8:00 and to the NRC i -Region 1 of fice sometime between 8 and 9:00 a.m.
There has been some belief that a 40R/hr predicted worst-case dose rate was calculated. This belief resulted from an error made by an -
i
- engineer .in transforming the predicted calculated worst-case dose rate .
i from his Off-Site Dose Calculation Sheet to his Radiation Correction
! Summary Sheet. As noted above, the initial predicted worst-case dose-1 rate for Coldsboro was calculated to be 20R/hr. When the wind speed l changed from 2 to 4 miles per hour, the engineer corrected the 20R/hr- -'
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doserateto10R/hrbyplacinga1overthe2(i0). In transferring this V .
number to his Radiation Correction Summary Shee'., the engineer misread the 10R/hr entry as 40R/hr, and wrote it as such on, the Radiation Correction Summary Sheet. In June-of 1979, the NRC Inspection and Enforcement group interviewed the two engineers involved in calculating the dose rates on [
l March 28. These engineers stated that a predicted dose rate of 40R/hr had ,.
been calculated for Goldsboro. Their statements were based on the above {
error made in transferring the '1'OR/hr figure from one sheet to another.
In July of 1979, Tom E$sig (NRC) was notified by one of the two engineers interviewed in June (Mike Benson) of the above error. However, Mr. E sig apparently did not relay this information to the appropriate persons, for NUREC 0600 was published with the 40R/hr dose rate.
In any event, it is clear that the engineer correctly read the dome monitor, correctly calculated the predicted worst-case dose rate for Goldsboro at 20R/hr, correctly adjusted this figure tc 10R/hr due to change in wind speed, and correctly calculated the real-case rate dose rate for Goldsboro to be less than 1 millirem /hr. based on actual reported field data. The 1 millires/hr dose rate negated the predicted worst-case dose rate, and was communicated to the NRC as soon as they returned our call. There were, never a calculated dose rate of 40R/hr for Goldsboro.
8
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. Inter-Office Memorandum .
, January 29, 1980 > i f FA SGTUEOG
,ect Interview with Brian Mehler Locanon MC40 TO FILE mum As part of the THI-2 Accident Investigation I met with Brian Mehler, Shif t Supervisor, to discuss two items 1) his perception of the cx:ent of the core damage on March 28 and 29 and 2) the status of the plant at the time he reported to the control room on March 28 and his subsequent actions. The following is a summary cf these discussions.
Extent of Core Danage Brian stated that he realized the core had been damaged as soon cs he saw the widespread indications of increased radiation levels throughout the plant. He associated this, however, with release cf the fission gas from some fraction of the fuel pins. He stated that to the best of his recollection, he did not recognize the true extent of core damage during March 28 or 29, and in f act, had little time for such considerations because of his other duties.
He also was not aware of anyone else who recognized the true extent cf core damage during that period. He suggested that we have a cimilar discussion with Jim Floyd.
Control Room Actions .
Brian reported to the Unit 2 control room at approximately 6:00 a.m.
cn March 28. He received some briefing from the night shif t which cpparently include ~d cons'iderable emphasis on the fact that the EFV - 12 valves had been erroneously closed. He then inspected various plant parameters and recognized the fact that coolant system pressure was abnormally low. He inquired whether the status of the pressurizer heaters had been chethed and although he was told that it was, decided to dispatch a foreman to double check their operability.
He then called up from the computer the temperature readings on the tailpipes downstream of the pressurizer relief and safety valves.
These readings shoued that the temperature downstream f rom the PORV was significantly higher then the temperature downstream cf either of ,the safety valves. Brian correctly deduced that this indicated that the PORV was still open and took action to close the PORV block valve. Subsequently he was involved in various support cetivities which we did not discuss in detail.
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N DEVELOPMDTr OF UNDERSTANDI'IG
/ ) ty>v o su The object of this task is to re-create, as best as possible, the a
1 chronology and an on-going status understanding of the ThE-2 accident i
as it developed.
It is obvious from the sequence of events and the response actions taken by the oparators that perception and understanding of the transient were changing, especially in the early hours. ,
! Levels of complication in assessing this developing undsrstanding 4
are introduced by the various com3unication interfaces which were j established about the data source. These interfaces provided data (as l well as on-going assessment) to an increasingly growing number of people j
Ns who int. urn contributed to what may be regarded as a conson understanding of the accident.
As time were on the number of commanication interfaces grew 4 .
geometrically,and became so interewined as to give rise to an apparent common pool of understanding. Consequently the task of unraveling the
~
growth of un'derstanding becomes increasingly more difficult as more 4
communication interfaces were established (later in time following the accident).
Necessarily then, the subject assessment must be attacked starting
-with the TMI-2 operator's understanding and procede through that of the i
site mapagament, Met-Ed management, CPU mtnagement, the CPU response team, and the industry advisory groap. Further the peripherical
- 4 i
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9 2-branches of BGT and NRC understanding could also be examined. Figure 1 attempts to illustrate the challenge and the scope of the above.
hc4i An analysis of the perception ofsignificant problems and growth *
! of knowledge during the event can be divided into three areas: #
i l A) Efforts to maintain control of the plant during the first four hours, 3) Assessment of the radiation emergency, and C) Perception
- of the non-condensable gas bubble in the reactor vessel.
A. Efforts to Maintain control of the Plant , .
During the First Four Hours of the Event, the main concern of the oparators was to bring the primary and secondary systems to a stable condition. Several key factors should be discussed to focus i .
on the basis for operator actions. Details used to formulate each of these key factors were derived from interviews with the shift suparvisor, shif t foreman and two control room operators.
- 1. Pressurizer I.evel Indication - From very early into the transient, operations personnel were very concerned with pressuriser 1
- level indication.
Within five seconds 'after the reactor trip the operator had started a second make-up ptr::p in anticipation of the expacted rapid decrease in
. */ . .
level never occurred, a,d within six minutes the pressuriser level was off scale high. The operato'es felt they had caught the expected level decrease with increased high pressure injectio2. The major concern of the operators at this point was to not take the R.C. system solid.
Based on high level indication and concern of taking the system solid, )
the oparator bypassed Safety Injection, stopped MUPIC, and throttled '
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( the MU-V16's. At this point RC pressure was still decreasing, and
- i j judgments were made primarily on pressuriser level based on either past experience during feedvater transients or reactor trips, training, or procedural guidan'ce. i
- 2. yailure of the Pressuriser Electrosatic Relief Valve to Close =
During the initial reactor coolant system pressure increase due to the .
turbine trip, the electromatic relief valve on the pressuriser opened, I as designed, at 2255 psi. After the reactor trip, the valve failed to : lose as pressure decreased through 2205 psi, although the operator 4
did verify that the valve indication did not signal an open valve. -
This valve remained open for the first two hours and twenty-two
)
] minutes of the event. Thus, the control room operators had failed to i
recognize a constant loss of coolant through the opsa relief valve for
!( that period. On at least three different occasions, the operators e checked the computer output for the thermocouple bands on the relief valve discharge piping to determine whether the valve had properly 1
seated as indicated; however, the computer data was misinterpreted 1
and the blo:k valve was not shut for two hours and twenty-two minutes.
I Readings from the the'rmocouple were in the range of 2303 -280'. The operator judged these valves to be quite low compared to pressuriser i j temperature (approximately 603 3
) and therefore concluded that the !
i electromatic must be closed. The operator did not rea11:e that the
.] temparature indication was from a thermocouple strapped to the outside of the discharge pipa and based os heat losses, readings in the range of 250' were an indication of an open relief valve.
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, During the cima that this valve was open, many other indications ,
of a loss of coolant accident ware present in the Control Room, such ,f as rapidly falling RC pressure, rapidly increasing RC drain tank '
pressura and temparatu're, increas'ing RB sump level while both sump pumps running, increasing RB temperature and pressure. Althotch *
. .. ... i ro n i'.
these indications of a,LOCA existed, the oparators did not associate -
them with the stuck open relief valve. The operators continued to focus on the initiating event (loss of feedwater) and attempted to deal with the consequences of that event on the condensate systea and the turbine heat sink.
- 3. Resetor Costant Pa=3 Coeratiot - At one hour and thirteen I
minutes into the event, two Reactor Coolant pumps were tripped due to observed "flov fluctuations" and allowable NPSH requirements of opar-ating fear RCP's. Approximately thirty minutes later the remaining two Reactor Coolant pumps ware t'rippsd based on similar concerns.
j Approxi=ately two minutes after the Reactor Coolant ptumps ware
] trippad, the oparator began to raise steam generator level from 1
thirty percent on the start-up range to fifty parrent on the operating range to further induce natural circulation. Within the next thirty minutes RC hot leg temparatures were increasing to off scale (greater than 520'). It was realized that natural circulation was not occurring probably due to a steam bubble formation in the A loop (the B loop vas isolated). Attempts ware made to again start a RC panp to force circulation through the core; however, attespts were aborted due to pump motor lov running current. (The 2B RC ptrup t
was run for a period of about 19 minutes some 75 minutes after the last p.c:p was tripped.). The 1A Reactor Coolant pxnp was started I i
i
i
, . t s approximately fourteen hours after all pumps had bee'n stopped.
- l l
I It appears that the actions of securing the Reactor Conlant j
) pays were ta'<en based on minimizing equipment damage (i.e. to
~
i prevent ptsap cavitation and protection of pmp seals) and not based
! os an understanding of what was occurring in the primary system.
, B. Assessment of the Radiation toernency - The growth of .
1 4
j knowledge in this area developed rapidly approximately two hours
{ and forty-five minutes into the event, as the first radiation r .
monitoring alacas were received throughout the plant. This know-l -
l 1 edge was accunnlated quickly, and used effectively to determine action levels according to the radiatios emergency plan. Although i the extent of fuel failure was not realized this early in the event, 1
l the perceptios of the significance of the radiation monitoring
{l y system reafir.gs was accurate.
C. Percontion of the Non-Condensable Gas Bubble in the Reactor Vessel - Early in the evening of March 29th, a group of ,
engineers set to discuss present plant status. Two of these engineers repsrted to the control room to back up the operating staff. By approst-mately 2103, it wa's apparent to this group that a non condensable bubble i
t
{ existed in the reactor coolant system. Prior to 2300, a formula was l
1 i
derived to calculate the size of the gas space in the system. Gas j bubble volumes were routinely calculated throughout the 30th of March 1
.! and calculated voltanes began to decrease late in the evening of the l i '
I 30th. Jased on analysis of the 3/28 reactor building pressure spike 1
j and containment air sa191e analysis which began at approximnesty 0400 t ,
1 a
on 3/31, it was determined that the gas bubble in the reactor coolant 1
I 6
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r system was primarily hydrogen. Volume of the gas space decreased 9
steadily through April 2. This was confirmed as the increase in hydrogen '.
a concentration of containment atmosphere leveled off as the bubble in the reactor coolant systes diffused.
Nee 3 The first management contnunications concerning the TMI-2 accident were "
l drafted in a telephone conversation between Mr. Herbein and Mr. Tabian At this time, they mutually approximately 7:15 a.m. Wednesday, March 28.
drafted a statement for response to press inquires that related that the TMI-2 reactor was shutdovn due to a malfunction in a feedwater system.
The antire unit systematically shutdown and was expected to be out of service for about a week while equipment is checked and repairs were made.
At approximately 9:30 'Jednesday morning, Gary Miller called Mr. Troffer
( to relate his conversations with t,t. Governor Scranton .concerning the unit status. During these conversations, Gary indicated that there was some fuel pin leakage, however, he noted that he didn't have any indication of fuel asit. The prepared statement to the press was updated l
by noon, March 28. .This statement revealed radiation levels were being l monitored in and around,the plant and that there had been no recordings of any significant levels of radiation and none were expected outside the plant. No avacuation of the to:a1 population was indicated at that l time and that the reactor was being cooled according to design by the reactor coolant system and should be cooled down by the end of the day, March 28. It added there was no danger of a weit down.
During the Met-Ed press conference in Hershey, on March 29, Mr. Herbein 4
said it was too early to tell the extent of the fuel damage'at TMI-2. !
L However, he noted that fuel failure had been experienced during the l
accident. He related this fuel failure to the point of turning off
- - --. o.. -. . . . 9, e . He updated the plant f
j status to say that a reactor coolant pump was running aid cosidown was ,
proceeding and that he expected to be on the decay heat system in ,
approximately 72 hours8.333333e-4 days <br />0.02 hours <br />1.190476e-4 weeks <br />2.7396e-5 months <br />. In response to questions from the press.
Mr. Herbein related perhaps one half to saa percent of the refs may have I
i experienced some melting and that the fuel had primarily failed due to
! the reactor coolant system depressurization and the need to shutdova t i
j the reactor coolant pumps. He noted that it was passible for some steaming in the uppar core region at that time that lesi to the fuel failure.
)I c
Early in the evening of Thursday, March 29, Mr. William Love,
} Mr. J. P. Moore had gone to the Unit 2 Control Rosa to assist the 4
j operating staff. Based on observed indications this groap assessed
- that there was a non-condensable gas bubble above the core. Later'that
- f. evening, calculations began to determine the volume of the gas bubble, i
,t ,
( During the press conference given on March 30, Mr. Herbein revealed i
the evidence of the gas bubble a'bove the core. However, he noted i
i that it appeared that the fuel assemblies were covered at that time
{ and that decay heat removal was progressing. He suggested at this i
time that the fuel failure was caused by a momentary uncovering of the fuel during the transient.
- t 1
- During the press conference on March 31, Mr. Herbein revealed that 1
efforts were underway to reduce the size of the bubble over the top p
of the fuel. Initial indications indicated that the venting process was suecessful and that the babble had reduced in size.
, He did mention '
I
- j. at this time, however, a concern that the venting process has lead to a i
butid up of hydrogen in the reactor building. During the evening a i i s l
J
- . 3 3
sa:nple of the reactor building atmosphere has been taken and that
! i at this cims there was no danger of an explosive mixture in the .' ,,
reactor building.
- 1 The first results of the reactor coolant analysis were received on Macch 30th. Based on these results, Mr. Herbein noted in the March 31 press conference that the core was indeed severely dasaged ~~
and that there was a possibility that a very large percentage of fuel assemblies were in the dan ged condition. This March 31 press conference was the last held by Met-Ed. After that time, comanications
! concerning the plant status were handled by the NRC.
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+ 2 (Whereupon, the deposition was concluded at e .3 , 3: 10 p.m.) >
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12 l 13 . . 11 i' I j. n, , Iti [ , 17 . 18 Dames P. Moore 19 Subscribed and Sworn to before me - 3t this -day of l , 1904
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UNITED STATES OF A! ERICA NUCLEAR REGULATORY C0bMISSION In the Matter of ) 4
)
MEIROPOLITAN EDISON COMPANY )
) Docket No. 50-289SP (Three Mile Island Nuclear ) (Restart - Remand on Mgt.)
Station, Unit No. 1 )
"IRANSOtIPT 00RRECTIONS -
Correction to transcript of deposition of James P. Moore taken September 26, 1984 ' Page Line(s) Change To Read 7 8 incue + instan+ 19 24 condency con clens 4+e
- 22. 2 Wa lis wati a ce 29 8 McYYIC MoofE SI E er if deyone Laat bh enyone CIN*d d.erac+ m 43 3 ' Jerry G "'y 44 84 or b at 5I t+ Svew n Svouf+==
si n emu.m*: b o3 +ews h s3 s m erl+ rese+ev 58 et z eveeni zecowiom 12 7 9 teaviAg be.ldvidi ' r:55 5 Yepvesstund.4 de preesS twiLC 14o 2.2. Qveg$ Faust- Cras$ Faust 140 22-23 tJed Fredrik Ken Freelevidk. 0 , ames P. Moorb ' i Subscribed and Sworn to before me this'
.- day of
. ..,- , 1984 Notary Puolic '
My Commission Expires: * :7 0759u <
UNITED STATES OF R4 ERICA NUCLEAR REGULATORY C0bNISSION In the Matter of )
)
MEIROPOLITAN EDISON COMPANY )
) Docket No. 50-289SP j (Three Mile Island Nuclear ) (Restart - Remand on Mgt.)
Station, Unit..No. 1 )
'IRANSCRIPT CORRECTIONS .
. Correction to transcript of deposition of James P. Moore taken September 26, 1984 Page Line(s) Change To Read 14e 7 operabM o b s ervat s*h l y t. 3 was over was ig- tags over ig y - 3, s &c.h ve ack 8 f It I 4 A Q i
3 ta 3 20 him N* ib 3 2O Ol*y I 343 as coels een+rol Yeom lb 5 4 CAPa down. L-6W e-1 (s. 8 7 C aN+ Col"- l l N s P. Moore Subscribed and Sworn to before me this N 'i day of
/ . . r s .: ,. , 1984 l
Notary Public - f.. -- ,...,.; r, - .. , My Commission Expires: ,:.
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177 i T ' I ; 1 ', . MS. BERNABEI: I have no'other questions. 23 (Whereupon,"the'deposi' tion-was-concluded at
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12 13 ' 11 I' i 15 Its 1.7 - 18 , yDemes P. Moore-i 19 . Subscribed'and
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..2Li - this, day of I 21:; 1984
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. .- UNITED STATES OF AMERICA NUCLEAR REGULATORY C0FMISSION In the Matter of )
)
MEIROPOLITAN EDISON-COMPANY )
) Docket No. 50-2895P (Three Mile Island Nuclear ) (Restart - Remand on Mgt.)
Station, Unit No. 1 )
'IRANSCRIPT 00RRECTIONS .
Correction to transcript of deposition of James P. Moore ' taken September 26, 1984 Page Line(s) Change To Read 7 8 i nc kle.+ instant 19 24 condmey can dens a+e 21 2. Wa its w aiia ce g_q 8 May $ 5 Moore. SI B er if aryone taas bef- =re dq.aviad d<rae m 43 3 gercy Gary bu* 44 14 or I si i+ Sveton Sreuf+-n ' si is eremow's h Scoo3 +ans 53 5 m crit reae+or 58 9 zercani Zkcow so m 12 7 Tr leavihg be.lsevidi 131 5 Yepresstwri.4 depressurig 14o 2.2. AreSS Foust- Cras$ Faust 14o 22 23 Ned Fredrik Ken Fransieme'K h s P. Moor 5 ' Subscribed and Sworn to before me this- . day of
'u < , 1984
/,
4 Notary Public . My Commission Expires: :7 i 0759u
' UNITED STATES OF AMERICA NUCLEAR REGULATORY C0bMISSION In the Fhtter of )
)
MEIROPOLITAN EDISON COMPANY ) I
~) Docket No. 50-289SP !
(Three Mile Island Nuclear ) (Restart - Remand on Mgt.) Station, Unit No. 1 )
'IRANSCRIPT CORRECTIONS .
I Correction to transcript of deposition of James P. Moore taken September 26, 1984 Page Line(s) Change To Read i40 7 eperaf M o b s ervai =n 15(. 3 was over was it- wits over ig 7 3s ach ve. ack 8 f Ic 4 A O I (a 3 2o -him N '" Ib 3 7o they I (,3 as carvtrols c anMI vaa* ! p,s 4 ca.p a a.wn. L-* w e 1( 9 7 C.an+ Can-I s P. Moore l Subscribed and Sworn to before me this n./. day of l
. r i . ,.
. ,'1984 1 I _ ., .
Notary Public < I
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My Commission Expires: ' :. 7 0759u ,.
12/12 s 13:51 GPU SERUlG ON'
- LNITED STATES OF AMBtICA NUCIJAR RBGUIAltRY CHUSSION In the Matter of )
)
MSIROPOLITAN EDISON COMPANY )
) Docket No. 50-2895P (Three Mile Island Miclear )
Statico, Unit No.1) ) (Restart - Reseand on $.) _SUFPLBGMT TO 1RANSCRIPr CURRECTION _ Correction to transcript of deposition of James P. More taken _ September 26 1984 - Page IJne(s) Change To Road 85 t7
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l l t y James P. M ore // ~ ~ Subscribed and Sworn to before me this & day of Jnu de.e , 1984 r) .. s .- ' t'L i ti, /} Notary Public
/L . Zh ra e My Commission Expires:
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